CDT Submits Comment on NIST’s Draft Report, “Reducing Risks Posed by Synthetic Content: An Overview of Technical Approaches to Digital Content Transparency”

On May 31, CDT submitted its comment to the National Institute of Standards and Technology (“NIST”) on its draft report “Reducing Risks Posed by Synthetic Content: An Overview of Technical Approaches to Digital Content Transparency.” CDT overall praised the draft report for providing a nuanced and thorough overview of the risks and benefits of existing and developing direct and indirect content-labeling techniques, as well as synthetic content detection methods. 

CDT offered three suggestions for potential improvements to the report.

• Our comment recommends that the report more fully address the challenges of scaling interventions like synthetic content detection and labeling systems. We suggest the report should do so by providing a path forward through a multi-stakeholder process that will more fully address the complexity and scale of coordination required to effectively implement the techniques discussed in the report and protect individual rights. 
• Our comment also takes note of the ambitious research agenda laid out by the report and recommends that the report identify entities that should be providing independent researchers access to data to accomplish this agenda. 
• Finally, CDT addresses the thorough discussion of detection and mitigation strategies for Child Sexual Abuse Material (CSAM) and Non-Consensual Intimate Images (NCII). CDT offers a few clarifying suggestions for expanding and adding detail to that section of the report.

Read the full comments.