The European Commission’s White Paper On Artificial Intelligence: our response

30 Jun 2020

By Richard Wingfield

GPD has responded to the European Commission’s consultation on its White Paper on artificial intelligence (AI), published in February. The White Paper set out the Commission’s proposals for measures relating to AI that it intends to take, inviting feedback on its specific proposals.

In our response, we acknowledge the many benefits that AI can bring, including greater opportunities to enjoy human rights—while also highlighting the risks it can pose to human rights, particularly to the rights to privacy and non-discrimination. We therefore conclude  that further efforts are needed, including regulation, to ensure that those risks are mitigated against.

Our response is delivered in two parts: a detailed set of answers to the specific questions posed by the Commission, and a standalone submission which analyses the proposals from a human rights perspective. 

Our submission makes a series of specific recommendations to the Commission on how to take forward the proposals in the White Paper in a way which will best ensure the protection of human rights. These include:

  • Steps the Commission should take to ensure that support for research and innovation on AI ensures that human rights are protected and promoted;
  • How education and training programmes related to AI could incorporate human rights considerations;
  • Ensuring that steps taken to support SMEs developing AI technologies, and public sector authorities procuring it, include capacity-building on human rights implications;
  • Critical elements of any new regulatory framework on AI, such as ensuring that any applications of AI which have the potential to significantly interfere with an individual’s human rights should always be considered as “high-risk”, and requirements for human rights impact assessments to be undertaken; and
  • Restrictions and safeguards on the use of facial recognition technology in public spaces, in order to mitigate risks to the rights to privacy and non-discrimination.



It’s not currently known when the Commission will respond to the consultation, or the exact next steps it will take. However, it is expected that the Commission will publish its response, and possibly any proposed legislation, in the early part of 2021.

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