Objectives for the sandbox process
The Norwegian Data Protection Authority and Ruter have identified two primary objectives that are related to potential data protection challenges in the development and use of Ruter's AI model.
Objective 1 - Development phase: Investigate the requirements for transparency when using personal travel data to develop artificial intelligence
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Delivery 1.1: Clarify what triggers the data subjects’ right to information regarding how their personal data is processed in connection with the development of artificial intelligence.
It will take time from the start of local collection of personal data until the first version of the service can be presented to users. An important question is what triggers the obligation to provide information. Among other things, it must be clarified as to when data pertaining to an identified or identifiable natural person is processed in accordance with the General Data Protection Regulation (GDPR), and when Ruter's responsibility for processing enters into force. -
Delivery 1.2: Clarify the data subjects' right to information in connection with the development of the AI model.
Ruter wishes to be transparent about how the customers' personal data will be used in connection with the development of the new functionality. To ensure transparency, it is important to be able to explain the purposes for the processing and how the personal data will be processed during the development of AI. Key questions are how much needs to be explained, and how to provide a good explanation before knowing what the AI model will become. -
Delivery 1.3: Identify issues relating to the requirements for information in connection with the development of the artificial intelligence when consent is used as a legal basis.
Certain special information requirements apply when consent is used as a legal basis. We want to identify what information is required to ensure that consent is valid.
Objective 2 - Usage phase: Investigate the requirements for transparency when using artificial intelligence on personal travel data
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Delivery 2.1: Clarify the various purposes for the processing of personal data during the usage phase, and what comes under the same purpose.
The purposes must be clearly stated even before the processing of personal data begins. We want to take a closer look at how the purposes in the usage phase can be specified. It can be difficult to define a clear purpose for the customer when Ruter themselves are still unaware of the full potential of the use of the personal data and machine learning. -
Delivery 2.2: Clarify the data subjects' right to information during the usage phase.
When using AI, Ruter also wishes to be transparent about how customers' personal data will be used. A key question is how to provide a simple and concise explanation to customers while at the same time providing an adequate description of what is taking place. How much of the logic behind the AI models must and should be disclosed when they are used for personal data? Another question is whether the AI model needs to be adapted to safeguard the various information requirements. -
Delivery 2.3: Identify issues relating to the requirements for information during the usage phase when consent is used as a legal basis.
The AI model will have to be further developed in parallel with customers using it in the Ruter app. We want to investigate what information a statement of consent will need to contain in order to ensure valid consent when the model is still under development.