EACB response to the consultation on the Draft Ethics Guidelines for Trustworthy AI

The European Associations of Co-operative Banks (EACB) welcomes the opportunity to provide its input to the consultation on the draft Ethics Guidelines for Trustworthy AI developed by the Commission’s High-Level Expert Group on Artificial Intelligence.

In its response, the EACB puts forward suggestions on three steps that the draft Guidelines could incorporate:

1) Assessment of the technical, social and (maybe) political risks of the use of AI technology;
2) Communication of the risks and benefits of AI technology to society; and
3) Ethical questions of the use of AI technology by human decision-makers.

Such approach would respond to comments raised by some Expert Group members under the section on critical concerns relating to AI. While some of these concerns are not necessarily directly related to AI itself, but rather to its use, and may not necessarily be translatable into guidelines, they do merit attention from an ethical perspective.

Overall, we believe that the Guidelines should recognise that the many different use cases of AI cannot always be subsumed under the same ethics principles. Such principles should apply predominantly, if not exclusively, to AI systems that are sufficiently complex and/or handle sufficiently sensitive areas.