Niti Aayog Discussion Paper, November 2022- Adopting the Responsible AI Principles: A Use Case Approach on Facial Recognition Technology

Abstract

We have prepared a set of comments and recommendations on the recent discussion paper released by Niti Aayog on Facial Recognition Technology (‘FRT Report’).3 We welcome the opportunity to provide our inputs and engage in participative policy making, particularly with regard to AI and its use in India.

Our comments cover two broad aspects. First, we provide some broad comments on the framing and rationale of the FRT Report. Second, we outline some specific suggestions for applying the Responsible AI Principles to facial recognition technologies.

Our aim is to encourage the development of nuanced, contextual policy for AI that: (i) accounts for the social realities in India, (ii) does not exacerbate or create new hierarchies of power, and (iii) is truly equitable and democratic. We believe that neither AI nor facial recognition technologies (‘FRT’) are neutral or objective technologies. These are technologies of power that both shape and are shaped by social, cultural, economic, and political factors. We urge Niti Aayog to adopt a similar approach to technology in policy outputs for AI.

Keywords: AI, FRT, Law, Policy, India, Niti Aayog