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Industry committee  No, no. I have lots of opinions about this.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  Maybe I'll answer really quickly.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  I think that what's really important is that there is a governance process put in place before those systems are developed. As I mentioned, that's part of this assurance or audit function that would exist. I also think, as I mentioned in my opening statements, that having an accountable person, something like a chief AI officer, would help work through that process in a consistent and therefore meaningful way.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  Yes, I do, and I think, too, a certain specification. That's why a standard would be good. The analogue could be a fair trade symbol or LEED, as I mentioned previously. Thinking about different types of standards that one would need to meet in order for that to go on the market should be a precondition for high-risk systems.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  As we've discussed a lot today, I do think it's a good start to understand that AI is not one thing. Breaking it down into different types of contexts and use is important. I think, though, that it's a limited list. I get that the concept is to continue to add to it and to have a process.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  As I mentioned, I think it could be a matrix of both the contexts that are being used and the recognition of what a standard high-risk assessment would be. Again, I would draw your attention to appendix C of the directive on automated decision-making systems, where that is broken down into four different types of impact, as we called it, but then different types of compliance requirements would be related to that.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  The requirement of harmonization across different ministries, I think, is really important. I would also flag the requirement of harmonization within Canada—interprovincially, as well as provincial to national government and local government, as well—which I think is quite important.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  That's why we worked on the directive on automated decision-making systems at Treasury Board Secretariat. That's the purview of management systems that Treasury Board is responsible and accountable for. Should that be raised to an act level, similar to where we see PIPEDA and a Privacy Act that governs how public sector services work?

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  The directive on automated decision-making systems does, though, oversee government's use of AI systems. One other additional thing is that we should, again, ensure alignment between these two due to the fact that most government departments aren't actually developing their own AI systems.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  It would be if no one is harmed. It's really difficult to address that. I think that, first, we need to try. We need to recognize that just leaving it to the free market is probably not going to result in the conclusion we want to see. There's an amazing resource called the AI Incident Database.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  With all respect to my fellow witnesses, I think we're moving way too slowly on this.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  I think there are two key points here. One is that we really need to have one point of accountability. There's a lot of interoperability between different types of AI systems, so knowing exactly.... If it's an automated vehicle, it might be very clear that this is going to fall into transportation, but if it's a health care system, it might have issues related to consumer protection or it might have issues related to the health and safety of somebody.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  I think I've shared repeatedly that I don't think AI is one monolithic thing. I do think that it needs to be broken down into sector-specific regulation. I think what AIDA does is provide a framework that is then dependent on other types of sector-specific regulation. There is no contesting that how this was done is problematic.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  If I have my way, yes, I would love that. However, there's one addition that I'd like to note here. One of the things that people talk about—as you would know—is that financial audits are lengthy and very expensive. However, there are a lot of tools we can use to expedite the evaluation of these systems now.

December 7th, 2023Committee meeting

Ashley Casovan

Industry committee  You're not the only one. It's something that I think is quite complicated. One note that came in the amendments was related to the role of auditing within the commissioner's office. Something I'd like to see is more proactive use of auditing to ensure compliance, as opposed to the powers of the commissioner to require an audit when there is something that percolates that's problematic enough.

December 7th, 2023Committee meeting

Ashley Casovan