Monitoring and reviewing the impact assessment [in HR Recycler]
In HR Recycler the consortium aims to develop a collaborative human-robot to aid workers in the performance of their heavy tasks in recycling plants of waste electrical and electronic (WEEE) materials. The objective is that workers and robots “collaborate” in a joint and synchronised manner. What are the impacts of such a development? How it might affect workers rights and society as a whole? One main tool to ensure legal and ethical compliance is the performance of an impact assessment.
An impact assessment evaluates the origin, nature and severity of impacts that the (processing) operations, real or hypothetical, of a specific project entail. The ‘architecture’ for impact assessment typically consists of three main elements, the ‘framework’, the ‘method’ and the ‘template’. A framework constitutes an ‘essential supporting structure’ or organizational arrangement for something, which, in this context, concerns the policy for impact assessment, and defines and describes the conditions and principles thereof. In turn, a method, which is a ‘particular procedure for accomplishing or approaching something’, concerns the practice of impact assessment and defines the consecutive and/or iterative steps to be undertaken to perform such a process. A method corresponds to a framework and can be seen as a practical reflection thereof. These two elements have been identified in D2.2, being public. Lastly, a template for the assessment process can be seen as a practical implementation of a method (i.e. a procedure therefor, comprising consecutive and/or iterative steps) for impact assessment, itself reflecting a framework therefor (i.e. conditions and principles).
Building on the TARES impact assessment (Truthfulness, Authenticity, Respect, Equity and Social Responsibility), elaborated previously in another blogpost, VUB continues to identify legal, ethical and societal impacts that the project technology might entail, and to provide recommendations. This exercise necessitates broadening the picture of the project, so as to include relevant societal concerns, instead of solely focusing on legal matters (e.g. data protection).
To report the first version of the TARES impact assessment, an initial template had been sent out, where all partners had to answer specific questions from a technical and end-user point of view. The process of impact assessment shall be receptive and collaborative, i.e. technology developers work alongside the assessor’s team. During the first version of the TARES impact assessment, several issues were identified, such as that 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 instance, as a recommendation, an independent observer role to collect consent forms is warranted. The results of the report are confidential, for the time being, due to legitimate secrecy, and are illustrated in D2.3. However, a summary of the process may be published in the future.
The next tasks comprise mostly monitoring, review and update – to be achieved periodically with three deliverables – reports. The continuity of the TARES impact assessment aims at anticipating the risks and at adopting a mitigation strategy with recommendations for the further development of the technology. As the system is integrated, tested and evaluated, VUB will repeat this impact assessment, in three phases every 6 months, reporting after each phase of the project pilots. This means that a similar questionnaire, duly adapted, will be shared with all partners, so as to monitor closely the progress of each phase and the compliance to the mitigation strategy and recommendations; the latter will be adjusted to take into account the responses received. Assessors are currently revising their IAs, because things do change and there is a need to keep up in order to appropriately address upcoming issues. By doing this, the impact assessment aspires to be a ‘living instrument’, that evolves with the project and is able to assess ongoing changes and impacts.
To that end, VUB and specifically d.pia.lab recently announced for public consultation the third policy brief, which proposes a template for a report from the process of data protection impact assessment (DPIA); this reflects the best practice for impact assessment and, at the same time, conforms to the requirements of the General Data Protection Regulation GDPR. By utilizing the template as well as its subsequent modifications after the public consultation, VUB aims to better structure and perform the monitoring and review phase (including updates) of the assessment process in HR-Recycler.
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Nikos Ioannidis & Sergi Vazquez Maymir
August 2020
