Submission to the Consultation on the Development of a Canadian Code of Practice for Generative Artificial Intelligence Systems

11 Pages Posted: 9 Oct 2023

See all articles by Andrew Clement

Andrew Clement

University of Toronto - Faculty of Information

Date Written: September 14, 2023

Abstract

This is a submission to Innovation, Science and Economic Development Canada's (ISED) consultation on the draft Canadian Guardrails for Generative AI – Code of Practice. It takes the form of an open letter to the ISED Minister, and focuses on the ministry's consultative process around both the Code and the Artificial Intelligence and Data Act (AIDA) more generally, as this is foundational to any substantive discussion of policy and the area that calls most urgently for improvement. The letter points out issues that have surfaced in the governance process that impair the prospects for an effective and democratically based AI regulatory regime. Without improving the governance process significantly, Canada also risks reputational harm in international fora as other states have done significantly better in this regard. Based on this assessment, the letter offers remedial recommendations for achieving better outcomes not just for the Canadian AI scene but for the broader public interest.

Keywords: Artificial Intelligence (AI) governance, public consultation, Canadian federal government

Suggested Citation

Clement, Andrew, Submission to the Consultation on the Development of a Canadian Code of Practice for Generative Artificial Intelligence Systems (September 14, 2023). Available at SSRN: https://ssrn.com/abstract=4572066 or http://dx.doi.org/10.2139/ssrn.4572066

Andrew Clement (Contact Author)

University of Toronto - Faculty of Information ( email )

140 St George Street
Toronto, Ontario M5S 3G6
Canada

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