January 18, 2022

WASHINGTON – Global tech trade association ITI offered guidance to the U.S. government as it seeks to gather more information on Artificial Intelligence (AI)-enabled biometrics technologies. In recent comments to the Office of Science and Technology Policy (OSTP), ITI provided a set of recommendations to inform the government’s work on a Bill of Rights for an Automated Society and elaborated on governance programs and practices that may be useful for OSTP to consider in the context of biometric technologies, including with regard to performance auditing and post-deployment impact assessment.

“We appreciate the opportunity to provide input on OSTP’s RFI on AI-enabled biometric technologies,” ITI wrote in its submission. “To the extent this information is used to inform the development of a Bill of Rights for an Automated Society, we encourage OSTP to focus on high-risk uses of AI-enabled biometric technologies, leverage existing standards and frameworks, align its efforts with other ongoing federal agency activities, and continue robust, diverse stakeholder engagement. We agree that facilitating trust in an era of digital transformation is essential and that important questions related to AI need to be addressed to help foster that trust. At the same time, it is important to keep in mind that there are beneficial uses of biometric technologies and encourage OSTP to consider how to support continued innovation should it seek to devise policy in this arena.”

ITI offered the following recommendations to OSTP as it develops a Bill of Rights for an Automated Society, including with regard to biometric technologies:

  • In considering any future policy action, OSTP should focus on specific, high-risk uses of AI-enabled biometric technologies, rather than on the technologies themselves;

  • In creating a Bill of Rights for an Automated Society, OSTP should take an approach that considers use-cases or applications of the technology, being cognizant to consider and differentiate between public and private sector uses;

  • OSTP should take care to disentangle and deconflict any future policy measures related to biometric technologies from existing governance frameworks and best practices, focusing on gaps that are not address elsewhere;

  • OSTP should align efforts to develop a Bill of Rights with other ongoing federal agency activities, including the effort being undertaken by NIST to develop an AI Risk Management Framework;

  • OSTP should continue to engage with stakeholders in developing any future policy response on AI-enabled biometric technologies, especially with developers, designers and deployers of AI technology;

ITI’s submission highlights its ongoing engagement on AI policy around the world. In 2021, it issued a set of Global AI Policy Recommendations and recently provided feedback on NIST’s efforts to develop an AI Risk Management Framework and the National AI Research Resource.

Read the full comments here.

Public Policy Tags: Artificial Intelligence, Cybersecurity, Data & Privacy