This submission to the Government’s consultation on safe and responsible AI provides general feedback on the proposed framework. 

Key recommendations

• Voluntary and co-regulatory models should be avoided in developing the regulatory regime as they are ineffective and not harmonised with global best-practice.
• Risk-based approaches to AI are a fruitful way forward but strict criteria around risk designation—including considerations around data provenance, uses and potential uses emerging from reductant capacities—need to be drafted to avoid creating perverse incentives to inappropriately decrease risk reporting.
• Australia’s approach to AI, including risk frameworks, should embrace the precautionary principle, and this needs to be reflected in any and all risk identification or mitigation measures.
• Data provenance needs particular attention when considering transparency across the AI lifecycle, and designating risk levels.
• The role of consumer choice, including meaningful consent and privacy considerations, needs to be factored in when considering risk designations and risk-mitigations.
• Particular attention needs to be given to ensuring that any regulatory regime enshrines children and young people’s best interests.