Submission to the High-Level Advisory Body on Artificial Intelligence (AI) on key issues of Global AI Governance

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ARTICLE 19 urges the High-Level Advisory Body on AI to establish a human rights-centred governance pillar to protect freedom of expression and privacy. The submission outlines a ten-point plan addressing risks such as automated content moderation, biometric surveillance, and threats to journalists, while calling for transparency, mandatory impact assessments, and a total ban on 'unacceptable' AI systems like emotion recognition.

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  • ARTICLE 19 argues that AI applications in both the public and private sectors can interfere with freedom of expression, particularly through automated content moderation on social media where AI often fails to detect "contextual nuance" and may excessively remove legitimate speech.
  • The submission highlights that AI-driven surveillance, including facial recognition and biometrics in public spaces, is used to profile individuals and predict criminality, and recommends that such surveillance only occur on a "targeted basis on grounds of reasonable suspicion".
  • AI poses specific risks to journalists, activists, and human rights defenders through bot network harassment, doxing, the use of generative AI for blackmail, and the ability to "de-anonymize" individuals, which threatens journalist-source confidentiality.
  • To address the opacity of machine learning, ARTICLE 19 recommends that developers of "high risk" AI systems provide meaningful public and civil society access to their activities and implement public registration requirements.
  • The document proposes that users of high-risk AI systems should be obligated to conduct and publish human rights impact assessments before deploying the technology.
  • ARTICLE 19 calls for a complete ban on AI systems that pose an "unacceptable risk" to rights, specifically naming remote biometric identification, biometric categorization using sensitive attributes, and emotion recognition.

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APA
Rowley, S. (2024). Submission to the High-Level Advisory Body on Artificial Intelligence (AI) on key issues of Global AI Governance. World Association for Christian Communication. https://waccglobal.org/submission-to-the-high-level-advisory-body-on-artificial-intelligence-ai-on-key-issues-of-global-ai-governance/
Chicago
Rowley, Saskia. Submission to the High-Level Advisory Body on Artificial Intelligence (AI) on key issues of Global AI Governance. World Association for Christian Communication, 2024. https://waccglobal.org/submission-to-the-high-level-advisory-body-on-artificial-intelligence-ai-on-key-issues-of-global-ai-governance/.
Wikipedia
{{cite press release |last1=Rowley |first1=Saskia |title=Submission to the High-Level Advisory Body on Artificial Intelligence (AI) on key issues of Global AI Governance |publisher=World Association for Christian Communication |date=26 February 2024 |url=https://waccglobal.org/submission-to-the-high-level-advisory-body-on-artificial-intelligence-ai-on-key-issues-of-global-ai-governance/ |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{rowley2024submission, author = {Rowley, Saskia}, title = {{Submission to the High-Level Advisory Body on Artificial Intelligence (AI) on key issues of Global AI Governance}}, publisher = {World Association for Christian Communication}, year = {2024}, month = feb, url = {https://waccglobal.org/submission-to-the-high-level-advisory-body-on-artificial-intelligence-ai-on-key-issues-of-global-ai-governance/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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