In our comment letter to the Working Party Article 29 draft guidelines on Automated individual decision-making and Profiling, ACCIS defends that the right of data subjects not to be subject to decision-making based solely on automated processing does not necessarily lead to the prohibition of conducts that data controllers should refrain from incurring, as interpreted by the Working Party Article 29. We also raise concerns with the elaboration in the draft guidelines on meaningful information pertaining to algorithms other than ‘finding simple ways to tell the data subject about the rationale behind, or the criteria relied on in reaching the decision’. In our view, it is necessary to maintain the balance between the EU fundamental rights and freedoms of data subjects and those of organisations to conduct their business and protect their intellectual property rights and trade secrets.
ACCIS comment letter to Working Party Article 29 draft guidelines on Automated individual decision-making and Profiling
Nov 28, 2017 | Managing Data