Innovation and Regulation: Attaining and Maintaining Transparency and Accountability in Automated Decision-Making

Within society, Automated Decision-Making (ADM) (a decision with no human involvement) is increasing. The retail sector uses ADM to profile and personalise content to its customers through Recommender Systems (RS). RS takes the information the organisation knows or perceives about an individual or group of people and applies an algorithm that predicts and recommends future purchases.

RS's perceived benefits are that the individual sees content that is more relevant to them and is cost-effective to organisations, and increases sales. As online retail grew over 30% between 2015-2018, and April 2020 saw e-commerce sales grow by 209%, keeping abreast of consumer interests and habits is particularly important for organisations to optimise survival chances. In contrast, RS present many challenges for individuals and society, primarily around privacy. As they work behind the scenes, many individuals may be unaware of RS, and studies continue to understand more about the ethical challenges and their real impact upon society.

This research concentrates on the policy aspects of RS with the General Data Protection Regulation. We seek to understand how organisations interpret this technology's use in line with the GDPR, particularly the application and distinction between general profiling activity, decision-making based upon profiling and automated individual decision-making, including profiling.

The GDPR is a key starting point as its general design is to bring clearer rights for individuals and provide more obligations and consequences for organisations. While the GDPR does not define transparency, we mean being 'clear, open and honest' to all and by accountability, we mean 'taking responsibility' and 'demonstrating compliance'.

To understand the current position regarding elements of transparency and accountability, we will consider the organisation's publicly available information and make use of our individual rights. Semi-structured interviews with organisations, individuals and regulators will also provide wide stakeholder feedback on RS transparency and accountability, both on the present position and what they feel may improve matters.

Overall, the project aims to understand the balance between organisations, individuals and society and make appropriate recommendations to inform the future regulation of ADM in RS for societal good.

We will collaborate with over 40 partners drawn from across FMCG and Food; Creative Industries; Health and Wellbeing; Smart Mobility; Finance; Enabling technologies; and Policy, Law and Society. These will benefit from engagement with our CDT through the following established mechanisms:

- Training multi-disciplinary leaders. Our partners will benefit from being able to recruit highly skilled individuals who are able to work across technologies, methods and sectors and in multi-disciplinary teams. We will deliver at least 65 skilled PhD graduates into the Digital Economy.

- Internships. Each Horizon student undertakes at least one industry internship or exchange at an external partner. These internships have a benefit to the student in developing their appreciation of the relevance of their PhD to the external societal and industrial context, and have a benefit to the external partner through engagement with our students and their multidisciplinary skill sets combined with an ability to help innovate new ideas and approaches with minimal long-term risk. Internships are a compulsory part of our programme, taking place in the summer of the first year. We will deliver at least 65 internships with partners.

- Industry-led challenge projects. Each student participates in an industry-led group project in their second year. Our partners benefit from being able to commission focused research projects to help them answer a challenge that they could not normally fund from their core resources. We will deliver at least 15 such projects (3 a year) throughout the lifetime of the CDT.

- Industry-relevant PhD projects. Each student delivers a PhD thesis project in collaboration with at least one external partner who benefits from being able to engage in longer-term and deeper research that they would not normally be able to undertake, especially for those who do not have their own dedicated R&D labs. We will deliver at least 65 such PhDs over the lifetime of this CDT renewal.

- Public engagement. All students receive training in public engagement and learn to communicate their findings through press releases, media coverage.

This proposal introduces two new impact channels in order to further the impact of our students' work and help widen our network of partners.

- The Horizon Impact Fund. Final year students can apply for support to undertake short impact projects. This benefits industry partners, public and third sector partners, academic partners and the wider public benefit from targeted activities that deepen the impact of individual students' PhD work. This will support activities such as developing plans for spin-outs and commercialization; establishing an IP position; preparing and documenting open-source software or datasets; and developing tourable public experiences.

- ORBIT as an impact partner for RRI. Students will embed findings and methods for Responsible Research Innovation into the national training programme that is delivered by ORBIT, the Observatory for Responsible Research and Innovation in ICT (www.orbit-rri.org). Through our direct partnership with ORBIT all Horizon CDT students will be encouraged to write up their experience of RRI as contributions to ORBIT so as to ensure that their PhD research will not only gain visibility but also inform future RRI training and education. PhD projects that are predominantly in the area of RRI are expected to contribute to new training modules, online tools or other ORBIT services.