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Faith-Related Organizations Submit Comments on the EU White Paper on Excellent and Trustworthy AI

Last February, the European Commission published a White Paper: On Artificial Intelligence – A European Approach to Excellence and Trust.  The White Paper seeks to create a policy framework for a common European approach to AI that will enable a trustworthy and secure development of AI to capture its benefits to individual and corporate citizens of Europe while fully respecting their values and rights.

The White Paper builds on seven key guidelines for Trustworthy AI established by its high level expert group in April 2019.  These include: human agency and oversight, privacy and data governance, transparency, diversity and fairness, societal wellbeing and accountability.  The Commission invited comments from a wide range of stakeholders including “civil society organizations.” The responses of two faith-related organizations have come to our attention.

The response of the European Evangelical Alliance (EEA) was crafted by a team of lawyers, technologists and other advisors across Europe. The EEA is an alliance of denominations and church organizations across Europe, seeking to serve an estimated 23 million evangelicals within the EU. Key points in the EEA response include:

  • At a foundational level, a concern “that economic and scientific development not take precedence over human flourishing and wellbeing.” The response called for a grounding of European values in clearly articulated ethical goals including a clear definition of such stated goals of the White Paper as “improvement of lives” and “better the lives of all citizens” lest it be assumed that economic benefit in itself would be a sufficient reason to move forward with an AI application.


  • A call for all AI applications to undergo a comprehensive risk impact assessment that would incorporate legal and regulatory risk, impacts on Human Rights and “ethical and societal impacts”. The risk impact assessment should feed into “a wider framework of AI and data ethics governance and oversight” within a well-established oversight organization.


  • A clear demarcation between human-created tools, which the comments called “artefacts” and humans themselves. Indeed, the comments took issue with the idea of “trustworthy AI” itself, noting that only humans should be worthy of trust.

The second commenting organization is the Center for Religious Studies of the Fondazaione Bruno Kessler (“FBK”) in Trento, Italy. The Center for Religious Studies is a secular organization that considers the role and purpose of religion in society. Its comments are entitled Engaging Religious and Belief Acts in the European Approach to Artificial Intelligence.

The FBK submission summarized its 10-year Strategy through 2027 seeking to advance “the critical understanding of the multi-faceted relationship between religion and innovation in contemporary societies, and . . . improving the interaction among religion and social and cultural innovation as well as innovation in science and technology.”  It made a case for religious and belief communities as “competent interlocutors on digital innovation”, stating that “the work at our Center shows there are various examples of innovations, technological or otherwise that have been adopted shaped and developed by religious or belief communities, including social media, digital games, virtual reality technologies and smart community applications.” It also flagged the “impact of scientists and entrepreneurs whose work on digital transformation and AI is guided by religion or belief.”

In responding to the White Paper proposals for creating an “Ecosystem of Excellence”, the FBK submission highlighted the importance of interdisciplinary participation by humanities and social science professionals.  It cited the likely need for a fundamental restructuring of research organizations and a broadening of the spectrum of collaborations to include “the activism of religious or belief communities and of individual believers and non-believers.” At the same time, the submission highlighted the need for digital education in the direction of religious or belief groups to help bridge the digital divide.

The FBK Comments predicated the creation of an “Ecosystem of Trust” on active engagement of faith communities. It offered as examples of how trust could be breached or broken by the use of algorithms to profile believers’ convictions and practices, digital tracing of persons entering houses of worship, and failing to prevent religious discrimination within algorithmic decisionmaking.

Both sets of comments provide excellent examples of sophisticated participation by European faith-related organizations in national/international policymaking. Many thanks to UK IP attorney Patricia Shaw-of Beyond Reach, who assisted in the drafting of the EEA comments and provided us with a copy of them; and to Brian Grim of the Religious Freedom and Business Foundation for calling our attention to the FBK comments.  Both Patricia and Brian also assisted and provided supplemental comments to the FBK submission.

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