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Home

Submission

Human rights and substantive equality must be front and centre in regulating Artificial Intelligence

Bill C-27: Regulating the impact and use of Artificial Intelligence

While artificial intelligence (AI) has been touted by industry as an innovative tool that will yield benefits for the public, examining the impact of AI from a substantive equality perspective reveals profound harms.

LEAF supports the federal government’s initiative to regulate the use and impact of AI through the proposed Artificial Intelligence and Data Act, which was introduced as part of Bill C-27. However, LEAF remains concerned about the absence of a human rights approach within the current proposal, including the lack of recognition of the collective harms that can result from the use of AI, and the range of different institutions and AI-systems that can cause such harms.  

As a leading national organization with a mandate to advance substantive gender equality, LEAF made recommendations in a brief on Bill C-27, which was submitted to the Standing Committee on Industry and Technology in September 2023. The submission was co-authored by Rosel Kim (LEAF Senior Staff Lawyer) and Dr. Kristen Thomasen (Assistant Professor, University of British Columbia Peter A. Allard School of Law, and Member of LEAF’s Technology-Facilitated Violence Advisory Committee). 

We urged the government to centre substantive equality and human rights as the guiding principles when regulating the growing use of AI.

Overview of Recommendations: 

  1. Government institutions must be included in the scope of AIDA;
  1. The statutory definitions of “harm” and “biased output” must be expanded;
  1. Harm mitigation measures must not be restricted to “high-impact” systems;
  1. “Persons responsible” for AI-systems must explicitly include those involved in system training and testing;
  1. “Persons responsible” should be required to perform an equity and privacy audit to evaluate the possibility and likelihood of harm and biased outputs in advance of using, selling, or making available an AI-system. This audit must also be published and made available to the public; and
  1. Substantive equality and public consultation must inform the development of regulations.
2023-09-11-LEAF-Submission-re-AIDA-final


Joint letter of concern regarding AIDA

LEAF also joined 45 expert organizations and individuals expressing serious concerns regarding the Act in a joint letter addressed to the Minister of Innovation, Science and Industry. Learn more about the AIDA letter.

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National Office
180 Dundas Street West, Suite 1420
Toronto, ON M5G 1Z8
[email protected]
Phone: 416.595.7170
Fax: 416.595.7191

Charitable Registration Number: 10821 9916 RR0001

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