Response to ICDPPC public consultation on Ethics and Data Protection in Artificial Intelligence

DIGITALEUROPE welcomes the International Conference of Data Protection and Privacy Commissioners’ (ICDPPC) Declaration on Ethics and Data Protection in Artificial Intelligence as well as the establishment of the related permanent working group.

Responsible development and use of artificial intelligence (AI) rest on a principled approach to data protection and privacy. AI doesn’t necessarily present a threat to these rights. We believe AI can be developed and used in a privacy-protective way. It can even enhance privacy, if developed and used correctly.

We hope this public consultation will contribute to a constructive debate on data protection and AI as well as to the future work of the newly established working group. We believe the Conference is well placed to enhance public debate on these topics, and we look forward to the working group’s contribution towards a better understanding of, and respect for, data protection principles in the development and use of AI.

We welcome the Conference’s ambition to operate within a global context and encourage the working group to take into account similar exercises driven by other stakeholders in the international community. The current policy discussions on AI around the world revolve around the same challenges and opportunities, and the nature of AI requires cross-regional policy approaches in order to appropriately address AI’s risks and enable its full benefits.

We support the acknowledgement of the need for data protection and privacy authorities to work with other authorities addressing human rights. Collaboration will need to go hand in hand with expert knowledge in order to generate fruitful discussions on AI. With the growing importance and volume of personal data processing, data protection and privacy authorities are challenged today in terms of human and financial resources. Their expertise needs to increase and remain specific in order to respond effectively to their tasks. Similarly, other authorities will have to strengthen their capacity and resources whilst maintaining their specific focus.

The challenges identified in the Declaration are accurate and reflect industry experience. We believe the Declaration identifies the right principles and provides useful input to the public debate. In our response we would like to provide input and comments on the Declaration’s specific guiding principles.