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On
March
6,
2023
the
Centre
for
Information
Policy
Leadership
(CIPL)
at
Hunton
Andrews
Kurth
filed
a
response
to
the
National
Telecommunications
and
Information
Administration’s
request
for
comment
on
issues
at
the
intersection
of
privacy,
equity
and
civil
rights.
CIPL
noted
that
the
civil
rights
implications
of
commercial
data
practices
raise
questions
addressing
responsible
uses
of
data,
and
CIPL
has
a
long
history
of
promoting
responsible
data
practices
through
its
efforts
regarding
organizational
accountability.
By
encouraging
organizations
to
implement
and
demonstrate
accountability,
CIPL
has
sought
to
ensure
not
only
that
organizations
comply
with
applicable
legal
requirements
and
best
practices,
but
also
that
organizations
improve
societal
trust
in
their
legitimate
and
beneficial
uses
of
data.
While
CIPL’s
Accountability
Framework
was
initially
developed
to
help
mitigate
risks
related
to
privacy
harms,
CIPL
noted
that
its
framework
and
the
risk
assessments
it
entails
can
have
broader
application
and
can
help
address
risks
associated
with
any
data
use,
including
harms
impacting
marginalized
or
underserved
communities.
Indeed,
a
contextual
risk
assessment
would
help
identify
not
only
potential
harms
to
members
of
a
particular
group,
but
also
appropriate
measures
to
mitigate
those
harms.
Importantly,
CIPL
stressed
that
a
risk
assessment
does
not
address
whether
certain
types
of
data
should
be
used
generally
or
at
all,
but
rather
whether
the
data
can
be
used
responsibly
and
with
appropriately
tailored
protections
in
a
specific
context
and
for
a
specific
purpose.
In
support
of
this
point,
CIPL
cited
Professor
Daniel
Solove’s
recent
article
“Data
Is
What
Data
Does,”
which
emphasizes
that
it
is
the
use
of
data
that
matters,
not
whether
it
is
sensitive
or
non-sensitive.
CIPL
specifically
noted
that
not
all
collection
and
uses
of
data
related
to
race,
religion
and
other
data
sets
commonly
regarded
as
sensitive
are
bad
or
harmful.
Indeed,
AI
systems
in
particular
need
diverse
data
sets,
including
data
commonly
regarded
as
sensitive,
to
understand
and
subsequently
limit
biased
and
discriminatory
outputs.
While
CIPL
agreed
that
certain
uses
of
data
may
have
an
adverse
impact
on
marginalized
or
underserved
communities,
an
accountability-based
risk
assessment
will
be
able
to
identify
such
impacts
and
distinguish
appropriate
uses
from
inappropriate
ones
and
will
enable
appropriate
safeguards.
CIPL’s
full
comments
are
accessible
here.
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