The ICO has issued it’s guidance on design and implementation of data protection and GDPR for AI which can be found here.  The ICO covers four areas or parts of guidance including

  • part one addresses accountability and governance in AI, including data protection impact assessments (DPIAs);
  • part two covers fair, lawful and transparent processing, including lawful bases, assessing and improving AI system performance, and mitigating potential discrimination;
  • part three addresses data minimisation and security; and
  • part four covers compliance with individual rights, including rights related to automated decision-making.

This guidance is a useful start but given the level of detail needed for activities such as data protection impact assessments for AI, a better offering would include an AI inspired tool to help learn and speed up AI compliance objectives. This is particularly true as the ICO is suggesting that DPIA’s be treated as a living document needing to be updated regularly. It uses an example of such a change where it gives the following example … ‘depending on the deployment, it could be that the demographics of the target population may shift, or that people adjust their behaviour over time in response to the processing itself. This is a phenomenon in AI known as ‘concept drift’.

The ICO also proposes “using state-of-the-art security practices and PET’s (privacy enhancing technologies) when using personal data in an AI context”. The guidance is good but providing tools to speed up the AI compliance process would be better , in my opinion. The burden on regulated firms can’t be understated not just for data protection and GDPR, but when combined with other regulatory frameworks which maybe industry specific such as PCI-DSS, Dodd-Frank etc.

The ICO has been good about providing templates, but now tools are what’s needed more than ever.

Dapro Technologies Ltd
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