Legal and Ethic requirements for HR-Recycler
The VUB is the legal and ethical partner of the project. As such, its role consists of identifying legal, ethical and societal impacts that the project technology might entail, providing recommendations and ensuring compliance to those elements by the Consortium throughout the entire project. The particularity of HR-Recycler is the introduction of a novel technology in the workplace and the risks that human-robot-collaboration and human-robot-interaction can create, for example if it could result in an evaluation of workers’ performance at work or could lead to a feeling of surveillance. At present, the VUB team is finishing the TARES impact assessment of the project (comprising an assessment of the impacts on data protection, ethics and privacy), the third deliverable of the sixth to be drafted by the VUB. The outcomes are positive, although stronger safeguards have to be thought through, since workers are considered to be ‘vulnerable subjects’ and consent to participate in the research project is not deemed to be freely given by data protection authorities. For example, the Consortium is well-aware of the need to ensure clear separation of sensitive personal data processed by research partners and end-users (e.g. health data), foresee an independent observer role to collect consent forms, look for workers’ feedback at several moments of the project development and take into account the impact on workers’ social and labour rights. One aspect that makes easier the implementation of these strong safeguards is that all Partners are very experienced and extremely active in executing the necessary identified recommendations.
The HR-Recycler project also contributed to a research output, helping to build up the second policy brief of the d.pia.lab ‘Towards a method for data protection impact assessment: Making sense of GDPR requirements’. Live discussions at each General Meeting are guaranteed, with themes ranging from ethics, artificial intelligence, data protection, privacy and data protection by design, and the General Data Protection Regulation in general.
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27 January 2020