FPF Submits Feedback and Comments on UNICEF’s Draft Policy Guidance on AI for Children

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Last week, FPF submitted feedback and comments to the United Nations Children’s Fund (UNICEF) on the Draft Policy Guidance on Artificial Intelligence (AI) for Children, which seeks “to promote children’s rights in government and private sector AI policies and practices, and to raise awareness of how AI systems can uphold or undermine children’s rights.” 

The draft policy guidance outlines nine requirements for child-centered AI, including to:

1. Support children’s development and well-being;
2. Ensure inclusion of and for children;
3. Prioritize fairness and non-discrimination for children;
4. Protect children’s data and privacy;
5. Ensure safety for children;
6. Provide transparency, explainability, and accountability for children;
7. Empower governments and businesses with knowledge of AI and children’s rights;
8. Prepare children for present and future developments in AI; and
9. Create an enabling environment.

In the feedback and comments, FPF encouraged UNICEF to adopt an approach that accounts for the diversity of childhood experiences across countries and contexts. The feedback highlighted the need to address the specific and unique challenges children from marginalized groups face, particularly as AI may create or exacerbate prejudice, inequities, and harm for children from these communities. FPF also identified opportunities for the guidance to include strategies, tools, and resources to instruct stakeholders on ways to operationalize the requirements. Finally, the comments recommended a greater emphasis on acknowledging children as active participants in developing AI systems and their uses, and the importance of empowering children with digital literacy and citizenship skills.

Earlier in October, FPF also submitted comments to the United Nations Office of the High Commissioner for Human Rights Special Rapporteur on the right to privacy to inform the Special Rapporteur’s upcoming report on the privacy rights of children. FPF will continue to provide expertise and insight on child and student privacy, AI, and ethics to agencies, governments, and corporations to promote the best interests of children. 

Learn more about FPF’s US and international work on youth privacy here