Ms Rebecca Keatinge:

To amplify that with respect to the EU's AI Act, it is an extremely complex regulatory structure. We have a very short space of time for it to be implemented so there is a need to accelerate the protocols that need to be in place and the information-sharing mechanisms. There will need to be statutory change to a number of regulatory mandates of the different bodies involved, including Article 70 bodies and Article 77 bodies. We are amenable to that discussion and we are available but it is not a discussion that has been been opened.

Second, there is a role for AI literacy and availability of information, specifically with respect to the rights framework. We have human rights and equality architecture, we have the Equal Status Acts, the Employment Equality Acts and our own Constitution, which has the prohibition on discrimination. We also have the Charter of Fundamental Rights. There is an overarching architecture and it is about making the links between that and the use of AI. The guidelines that have been issued are something of a starting point. However, it is important that the messaging and the narrative capture that side so that we can pre-empt a procurement stage from the start of the life cycle of AI and it is captured within that broader architecture.

As a legal practitioner by trade, I know that detecting discrimination in the use of AI is extremely difficult. For individuals to try to enforce rights in this space, it is difficult to identify how algorithms are being used, how they are working and how they are impacting on individual citizens. There could be consideration of Departments being clear as to how they are using AI and in what deployments and circumstances. That falls quite neatly under the public sector and equality duty ongoing assessment of how it is impacting on and intersecting with human rights and equality concerns for service users.