12 November 2019

[T]he Council of Europe expert committee finalised recommendations on the human rights impacts of algorithmic systems. Access Now welcomes the paper with great enthusiasm. We especially appreciate the high level of expertise reflected in the guidelines for states and private-sector actors addressing the impact of algorithmic systems on individuals’ human rights. We urge the member states to adopt the text in due course and ensure its implementation by both the public and private sector...

We will analyse the revised recommendations based on our suggestions submitted in the consultation process as outlined below. 

In our response to the consultation we first  (1) outline our suggestions for further edits of the main principles stated in the recommendation’s preamble; then (2) propose concrete improvements for the guidelines governing states’ obligation and private-sector actors’ responsibilities to protect the human rights of online users in the context of algorithmic systems; and finally (3)  emphasise the most essential elements of the guidelines that Access Now fully supports and has been advocating for in our own work...

The right to freedom of assembly needs to be explicitly addressed...

Conducting human rights impact assessments for algorithmic systems deployed by public authorities  should be mandatory for states...

Private-sector actors that develop algorithmic systems should comply with industry standard human rights due diligence frameworks...