Ms Noeline Blackwell:

I thank the Chairman and committee for the opportunity to address them on the topic of AI and children. As members have heard directly from the mouths of young people, children and young people live in this digital environment and are entitled to the full exercise of their rights in this environment. Our presentation and the longer briefing we also circulated focus on children’s rights. Our foundation, like other organisations here, is the UN Convention on the Rights of the Child, which as members will know has been signed by every country in the world bar one, and the specific comment made by the committee of that convention in 2021, which makes it easier for us to focus on the main issues within children's rights. That is general comment 25, a term we are likely to use without explaining what it is a comment on.

It is a comment on children-specific rights in the digital world. In focusing on the committee’s terms of reference, today we hope to support it in understanding how Ireland better produces and deploys AI safely and ethically in a way that brings societal benefits while safeguarding rights and mitigating risks. Inevitably, given the speed at which AI is moving and the size of the generative AI world, we will be focusing on safeguarding rights and mitigating risks for children and young people.

I will gallop through the recommendations we have made to the committee. First, there is a need for a child-rights approach so that AI products and systems are inherently safe. In many ways, this is at the heart of it. If we had safe products, a lot of our problems would not exist at all. Currently, systems are not designed with child safety in mind. We recommend that all AI providers and deployers should be required by law to ensure that AI systems are safe for children by design and by default, and that systems should consider children’s views and ensure there are effective reporting and complaints systems. We also recommend that the national digital strategy, which in its current version does not do this, specifically consider children’s rights.

Second, looking at the EU AI Act, we recognise that it is a very innovative piece of legislation and that someone has to start somewhere, but there are gaps in protection in the Act. There is no mention of recommenders, insufficient recognition of the chatbots that children find engaging and the potential for deepfake technology to do real and lasting damage to children’s lives. We hope that when Ireland is asked for its views on the new general code of practice, the committee might take the opportunity to read it with a child-rights lens.

We also notice the speed at which child sexual abuse material can be generated, deployed and spread worldwide, particularly through deepfakes and the like. We recommend that the committee urge the Oireachtas to pass the necessary legislation to keep children safe in Ireland and to ensure that at European level this also happens. The Ombudsman for Children’s representative spoke about education. There is also the issue of children’s data in the various edtech programmes that are going into schools.

Finally, inevitably, we mention resources. Nine bodies are tasked with protecting fundamental human rights under the EU AI Act. They have been announced for the best part of a year. They include the Ombudsman for Children and the Irish Human Rights and Equality Commission. We have heard nothing about the resources and training needed for those bodies. They will be crucial to making sure children’s rights are protected online.

My colleague Alex Murphy and I are happy to answer any questions.