SIENNA response to the public consultation on UNICEF’s draft Policy Guidance on AI for Children



On 16 October 2020, the SIENNA project submitted its response to the UNICEF public consultation on draft Policy Guidance on AI for children. Our key recommendations were to address concerns related to “digital inequality”, call for AI that respects human rights, and adopt a stronger stance on problematic technologies.

(Image removed) We welcome UNICEF’s initiative to explicitly address the impacts of AI on children and found the guidance on data protection and privacy rights to be useful. We were also pleased to see the inclusion of a multi-stakeholder approach in impact assessment for governments and business, particularly in the accompanying implementation tools.

Our key recommendation was to refer to ‘digital inequality’, in contrast to ‘digital divide’, when discussing the spectrum of access and control levels, and the related impacts on children. If nothing is done to address this challenge today, these inequalities will be exacerbated further. Furthermore, we cautioned against an overly optimistic view of the benefits AI can bring to children that fails to account for the severe risks. Human rights should be foundational to all these discussions, therefore we also urged adding a requirement that AI must be developed, deployed, and used in a way that does not violate (or enable violation) of children’s human rights. Additionally, recognising that we don’t yet know all the impacts of AI on children, we strongly recommended the Guidance call for more caution, including setting red lines for the deployment and use of AI in certain children’s settings.

In addition to the use cases already explored in the Guidance, we recommended several critical applications that should be added, including emotion-detection technology, surveillance and facial recognition, and AI-powered assessment tools for learning. We also recommended enriching the use case discussion with insights regarding children’s behaviour, conformity to robots, as well as discussion of the long-term impacts that AI will have on children’s free will, decision-making capacities, intellectual development, socialisation, and understanding of what it means to be human.

Read more about the UNICEF public consultation on draft Policy Guidance on AI for children on their website.

Read SIENNA's response (Link removed)

By Nicole Santiago, Trilateral Research





Project structure


Disclaimer: This website and its contents reflects only SIENNA's view. The Commission is not responsible for any use that may be made of the information it contains.