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  • Writer's pictureChristina J. Colclough

Audits & Impact Assessments 2.0

Across the world, a new wave of audits and/or impact assessments for digital technologies are popping up. None include workers in the process. This must change, argues this blog.


Jonathan Guy from the Australian Education Union (AEU) argues in this powerful article why unions need to be party to audits concerning the need, use and impact of digital technologies. Jonathan provides a convincing case:

As a response to the closure of schools due to the pandemic, the Australian Federal Government lowered the price of broadband. But research the AEU had just conducted showed that although a small proportion of all students in Australia (5%) do not have internet access on any device, public school students are overrepresented among those without access: 125,000 of them have no internet access on any device and they were 2.5 times more likely than private school students to have no internet access at home. Aboriginal and Torres Strait Islander public school students were four times as likely as non-Indigenous students to have no internet access at home—21% vs 5%. The study also revealed that almost a third of students living in very remote areas have no internet access. Students from low-income households, 80% of whom attend public schools, are 9 times more likely to lack internet access at home than students from high income households.

Guy, rightfully, remarks:

the government initiative is of little use to those without devices or existing broadband connections.

Jonathan Guy calls for digital equity audits that should be carried out at a national level together with education unions in order to provide evidence for comprehensive action plans. They must also take into account the relationship of COVID-19-related remote learning and ongoing disadvantage due to: lack of digital inclusion, potential long-term impact on the achievement of students by home internet access, family income, remoteness, mobility, family type, English proficiency, disability, housing, and Aboriginal and Torres Strait Islander status.

The point here is that had the Australian government reached out to the very unions who know what is at stake in the education sector, their federal solution would have been far more nuanced.

Back in Vogue

The call from Jonathan Guy is significant, and unions from all sectors should echo it. However, whilst audit and impact assessments are back in vogue across the world, and many models are being created, none, simply none, include the workers and their unions. The Ada Lovelace Institute published a report in 2020 "Examining the Black Box" - it includes this overview of assessing algorithmic systems. Again none include the workers nor the unions:

ForHumanity - an all-volunteer organisation aimed to bring together experts who are convinced that mitigating risk from the perspective of Ethics, Bias, Privacy, Trust, and Cybersecurity in autonomous systems will lead to a better world. They created a taxonomy that distinguishes between 3rd party independent audits, internal audits, assurance, consulting, and more. Again nothing is mentioned about the employees/unions' role in participating in, or approving, audits.

Unions must respond

Whilst especially industry is pushing for - albeit slightly improved - audits and impact assessments, we should also expect they are doing so in the hope to avoid more intrusive regulation. In my work in the OECD One AI expert group and elsewhere, I have read a growing number of company audit and impact assessments. None of them include the workers' voice. This even within the EU, where companies are actually obliged to create data protection impact assessments (DPIAs) and to consult with the workers when digital technologies process workers' personal or personally identifiable information.

So what's the problem?

Whilst the majority of the audits I have seen actually include articles on human rights, social, fairness and equity impacts, if these audits are conducted by management alone, it is - honestly - hard to take them seriously. We must, for example, ask "fair for whom"? For an individual, for groups, what groups? What is fair for one group might be very unfair for another. What compromises is the company making, and do the workers agree? If not, what are the remedies? The failure to meet the real challenges in Australia as portrayed in Jonathan Guy's blog, so clearly shows how the government response could have been far better had AEU be included.

By excluding the staff reps/shop stewards, and therefore the voice of the workers, companies risk approving potentially highly discriminative algorithmic systems. Trade unions have traditionally been the guardians of inclusive and diverse labour markets. The staff reps/shop stewards are also those closest to the workers. They know the sentiments of their colleagues and the lived experiences of discrimination, privacy violations and exclusion. No workplace or labour market audit system or impact assessment is worth the paper it is written on, if the voice of the workers is not an equal partner in its formation.

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