WPF advises that DHS biometric collection proposal needs scientific, factual, ethical, and human rights basis, urges creation of transparent multistakeholder process to work on ethical guidelines regarding childrens’ biometrics

The World Privacy Forum filed comments with DHS regarding its proposed new rules regarding biometric collection, and asked DHS to reconsider the rule and to apply the science, ethics, and international conventions regarding the protection of victims of human trafficking to the rule prior to moving forward. WPF found that the proposed rule avoided discussion of the new barriers it would create for vulnerable populations, including victims of crimes such as human trafficking. Further, the DHS proposal outlines a significant expansion of the utilization of biometrics for individuals of all ages, including children and infants, a collection which is scientifically questionable and fraught with ethical questions and problems.

Remarkably, the proposal did not discuss the well-documented issues regarding biometrics for people at the younger and the older ranges of the age spectrum. In the landmark NIST study by Patrick Grother, Mei Ngan, and Kayee Hanaoka, (Face Recognition Vendor Test [FRVT] Part 3: Demographic Effects in Facial Systems, NIST, December 2019) NIST wrote: “We found elevated false positives in the elderly and in children; the effects were larger in the oldest adults and youngest children, and smallest in middle aged adults. The effects are consistent across country-of-birth, datasets and algorithms but vary in magnitude.” These facts were not reckoned with in the DHS proposal.

For these and multiple additional reasons WPF discusses in its comments, WPF has urged DHS to rescind the rulemaking, and to take a step back and institute a formal multistakeholder process inclusive of the public to create robust ethical guidelines for the use of biometrics with children. There are already good models of how some governments are approaching this kind of undertaking. In the UK, a data ethics advisory service (Biometric Forensics Ethics Group) is providing guidance and support to Home Office projects. It utilizes the data ethics framework developed by the Department for Digital, Culture, Media and Sport.

WPF’s complete comments are available here: (PDF, 12 pages) WPF Comments to DHS regarding biometric collection

Posted October 14, 2020 in AI, Biometrics, Privacy Ethics, US Department of Homeland Security

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
National IDs Around the World — Interactive map

About this Data Visualization: This interactive map displays the presence...
Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.