Feedback from The Alan Turing Institute on the Digital Regulation Cooperation Forum’s Plan of Work for 2022 to 2023

The Digital Regulation Cooperation Forum (DRCF) was formed in July 2020 by the CMA, the ICO and Ofcom to support regulatory coordination in online services, and cooperation on areas of mutual importance.

The Alan Turing Institute welcomes the publication of the Digital Regulation Cooperation Forum’s Plan of work for 2022-2023 and its focus on the overarching goals of coherence between regimes, collaboration on projects, and capacity building across regulators.

The Alan Turing Institute’s feedback on the Digital Regulation Cooperation Forum (DRCF)’s Plan of work for 2022 to 2023 synthesises the perspectives of researchers at the Turing with expertise and interest in the area of AI regulation. The Alan Turing Institute is committed to supporting the DRCF in its mission and as such, has engaged with this plan and made a number of recommendations. The researchers who have contributed to this response are part of the public policy programme at The Alan Turing Institute. 

About The Alan Turing Institute

The Alan Turing Institute (‘the Turing’) is the UK’s national institute for data science and artificial intelligence (AI). Our mission is to make great leaps in data science and AI research in order to change the world for the better. Today, we are a community of more than 500 researchers, a growing team of in-house research software engineers and data scientists, and a professional services team. We convene activity across the data science and AI community through partnerships with universities and research institutes across the UK, as well as with industry, third sector and public organisations, with nine strategic partnerships.

About the public policy programme

The Alan Turing Institute’s public policy programme works alongside policy-makers to explore how data-driven public service provision and policy innovation might help solve long-running societal problems. The programme also works hand-in-hand with regulators to develop practice-based guidance and standards for the responsible development and use of data science and AI.

Executive summary

The Turing sees the existence of collaborative regulatory initiatives like the DRCF as essential to the UK’s ambition to be a global leader in the regulation of AI. Developing an effective and inter-organisationally robust regulatory environment is crucial for mitigating the far-reaching risks associated with AI. We welcome the DRCF’s plan of work for 2022 to 2023 and we value its focus on the overarching goals of coherence, collaboration, and building capability. Informed principally by our public policy programme’s research, we offer the following recommendations on the plan.

Coherence

• In addition to the indisputable needs identified in the report, we recommend activities such as the development of a shared vocabulary to provide conceptual clarity for AI regulation, and comprehensive mapping of the risks that AI technologies pose across regulatory remits.
• For protecting children online, we highlight the need to develop an evidence base and improve understanding of age verification, including the risks associated with outsourcing to third parties and using biometric data.
• We recommend prioritisation of research into the relationship between online engagement and children’s development, including the development of ways to involve children in such research.
• We recommend that DRCF consider incorporation of the principles from UNICEF’s Policy Guidance on AI for Children.
• Regulation of online advertising that negotiates the trade-off between individual rights and public benefit will require the enforcement of powers with respect to data sources; the pooling of expertise across regulators, and inclusive and participatory forms of democratic deliberation.

Collaboration

• The Turing has deep pockets of expertise and foundational work in algorithmic transparency. We are keen to support DCRF’s work in this area.
• We recommend a nuanced, interdisciplinary and practice-based approach to transparency that considers the transparency of processes, institutions and outcomes. We provide examples of the Turing's research that can inform this approach.

Capability

The Turing has conducted research to understand the capabilities of UK regulatory bodies in relation to AI, both in terms of regulation of AI and the use of AI technologies as regulatory tools.

We recommend that DRCF:

• build regulatory capability by developing skills across the regulatory landscape: fostering senior management understanding and buy-in; making training, skills development and tools across and beyond DRCF’s constituent regulators.
• consider the rapidly evolving field of AI standardisation as an important area of capability building. The Alan Turing Institute has been selected to lead the pilot of the AI Standards Hub set out in the government’s National AI Strategy and we would be delighted to collaborate with the DRCF with a view to enabling capability building in this area.
• encourage the broadening of stakeholder engagement, particularly citizens, through the incorporation of experiental expertise (taking account of end-user experience) in capacity building.