CDT appreciates that the guidelines highlight the “massive” data protection implications of a free adoption of facial recognition technologies.
In particular:
We agree with the EDPB that video surveillance should remain the exception and not the rule, even when talking about security purposes. The Draft Guidelines reiterate that organisations must justify their use of video monitoring, even for security-related purposes, but the EDPB should provide more guidance and clarification as to how this must be done initially and over time.
We appreciate the Draft Guidelines proposal to encourage multi-layered notices. However, we think that merely appending biometrics and profiling disclosures to existing CCTV signs is not adequate.
Furthermore, any such transparency effort should also be separated from any discussion of consent by a data subject to the use of FRTs.
Finally, we think that care should be taken that datasets built with facial analysis algorithms are developed in an ethical and transparent fashion. The EDPB is well-positioned to clarify how organisations may process video and image data for research purposes to improve FRTs and facial analysis algorithms.
As Brussels starts emptying for the summer, the risks of frontier AI models continue to capture the attention of policymakers as a key chapter of the AI Act becomes enforceable, and disclosure rules around the use of AI systems and AI-generated content are further clarified.
CDT Europe’s Feedback on the Draft Guidelines for the Classification of High-Risk AI Systems under the AI Act
CDT Europe responded to the European Commission’s consultation on the draft guidelines for the classification of high-risk artificial intelligence systems.
Open Joint Letter on a Public Reassessment of the EU-US Adequacy Decision
On 29 June, the US Supreme Court ruled that US President Trump can remove the leaders of independent agencies and commissions, overturning nearly 90 years of precedent limiting executive power. This decision raises serious questions about one of the key safeguards underpinning the EU-US Data Privacy Framework adopted in 2023: independent supervision.
Open Joint Letter on the AI Act Regulating AI-embedded Medical Devices
CDT Europe and other 5 organisations representing standardisation, consumers, digital rights, doctors, pharmacists and hospitals published an open joint letter calling EU policymakers to maintain medical devices under the scope of the AI Act.
