Data Trusts as an AI Governance Mechanism

Abstract

This paper is a response to the Singapore Personal Data Protection Commission consultation on a draft AI Governance Framework. It analyses the five data trust models proposed by the UK Open Data Institute and identifies that only the contractual and corporate models are likely to be legally suitable for achieving the aims of a data trust.

The paper further explains how data trusts might be used as in the governance of AI, and investigates the barriers which Singapore's data protection law presents to the use of data trusts and how those barriers might be overcome. Its conclusion is that a mixed contractual/corporate model, with an element of regulatory oversight and audit to ensure consumer confidence that data is being used appropriately, could produce a useful AI governance tool.