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Centre for Information Policy Leadership at Hunton Andrews Kurth LLP

CIPL

The Centre for Information Policy Leadership (CIPL) is a global privacy and data policy think tank based in Washington, DC, Brussels and London.

Lobbying Activity

Response to Requirements for Artificial Intelligence

29 Jul 2021

CIPL welcomes the Consultation on the European Commission’s Proposal for a European Artificial Intelligence Act to feed into the EU legislative process. CIPL is pleased to see that the AI Act incorporates several recommendations made in CIPL’s paper on Adopting a Risk-Based Approach to Regulating AI in the EU. In particular, CIPL welcomes the Act’s risk-based approach that would apply to high-risk AI use cases while not regulating the AI technology itself or entire sectors. CIPL also welcomes the proposed use of harmonised standards and industry self-assessment of product conformity, as these mechanisms have proven successful in driving innovation and developing safe and trusted technologies in the EU market. CIPL also welcomes the measures designed to support innovation, in particular by providing a statutory basis for regulatory sandboxes. Finally, CIPL is pleased to see that some of the requirements outlined in the AI Act align with some existing industry practices, which set a high bar to ensure that AI is developed and used responsibly. CIPL regrets, however, that the AI Act does not sufficiently account for imperatives such as providing for outcome-based rules; clearly enabling organisations to calibrate compliance with the requirements based on risks and benefits of the AI system; rewarding and encouraging responsible AI practices; leveraging takeaways from regulatory sandboxes; and clarifying that the AI Act’s oversight and enforcement provisions should also be risk-based. CIPL reiterates that for the AI Act to be effective in protecting fundamental rights while also laying a foundation for a new era in EU innovation, it needs to be flexible enough to adapt to future technologies. Further, the Act must not be overly restrictive so as to avoid suppressing valuable and beneficial innovations and uses of AI across a range of industries and sectors including public health or environment. Finally, the AI Act would benefit from targeted adjustments to better clarify the balance of responsibilities of AI providers, deployers and users, particularly for general purpose AI and open source AI models.
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Response to Legislative framework for the governance of common European data spaces

5 Feb 2021

The Centre for Information Policy Leadership (CIPL) welcomes the opportunity to respond to the Commission’s Consultation on the proposed Data Governance Act (DGA). The DGA is an important step within the EU’s broader Data Strategy, as it focuses on facilitating data access and availability while enabling and promoting trust in data sharing. As the Commission has consistently recognised, data is a fundamental building block to modern society—essential to providing important services as well as unlocking key innovations through big data, artificial intelligence and other emerging technologies. Data sharing and data access have assumed greater importance to help facilitate these innovations, as aptly demonstrated by the global response to COVID-19. CIPL commends the Commission’s continued emphasis on data-driven innovation and agrees with the Commission regarding the importance of data sharing and data availability. CIPL also supports the broader effort to promote the re-use of data collected by public entities for the benefit of the common good. The DGA considers a wide range of issues, using a holistic lens to address availability of data, opportunities to use data for social and economic good, availability of data for small and medium enterprises, interoperability, data infrastructure, data protection and cybersecurity. CIPL’s Response to the Consultation focuses on the data protection aspects of this conversation, while offering general comments regarding the importance of promoting and facilitating the responsible use and sharing of data. CIPL’s comments are applicable to the DGA specifically as well as more broadly to the upcoming proposals of the European data strategy on data spaces, high-value data sets or the future Data Act.
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

Please find attached the comments of the Centre for Information Policy Leadership (CIPL)
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Response to Commission Implementing Decision on standard contractual clauses between controllers and processors located in the EU

10 Dec 2020

Please find attached the comments from the Centre for Information Policy Leadership (CIPL).
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

15 Jul 2020 · To discuss White Paper on Artificial Intelligence

Response to Report on the application of the General Data Protection Regulation

28 Apr 2020

The Centre for Information Policy Leadership (CIPL)’s response consist of a Paper (attached) that builds and expands on CIPL’s 2019 report “GDPR One Year In: Practitioners Take Stock of the Benefits and Challenges” (see https://www.informationpolicycentre.com/uploads/5/7/1/0/57104281/cipl_report_on_gdpr_one_year_in_-_practitioners_take_stock_of_the_benefits_and_challenges.pdf), which summarised the benefits, challenges and unfulfilled promises of the GDPR for organisations. CIPL confirms that in 2020 the tangible benefits of the GDPR are still evident but, unfortunately, so are the challenges already highlighted in 2019. Yet, organisations continue to invest significant resources into GDPR compliance while technology continues to evolve and to create tensions with legal norms. In addition, the COVID-19 crisis has also put in sharp focus the need for progressive GDPR interpretation while confirming the enormous potential of data in helping to address this worldwide crisis. This ever-changing environment and the promises of beneficial data uses call for a shift in the approach to leverage the GDPR provisions to their fullest extent going forward. CIPL considers that because of GDPR’s principle-based, outcome-based and risk-based approach, it constitutes a solid foundation for building effective protection and trust for individuals while enabling the digital economy, including at time of crises. CIPL’s Paper does not advocate for a formal review of the GDPR at this stage, as it believes that the current challenges can be resolved by the Commission, the EDPB and the data protection authorities (DPAs) using the existing institutional and regulatory mechanisms and their wide interpretative powers. Finally, CIPL believes it useful to consider the current challenges of the GDPR beyond the limited points in Article 97(2) GDPR. CIPL’s Paper groups comments and recommendations in four categories: (1) Short-term actions to make GPDR implementation more efficient, including on Article 97(2) topics; (2) Improvements to the EDPB and DPA collaboration and engagement; (3) Progressive interpretation of some of the GDPR’s key substantive requirements; and (4) Long-term positioning of the GDPR in the broader digital landscape.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

22 Jan 2020 · Artificial intelligence

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

19 Dec 2019 · Presentation of CIPL EU AI white paper