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1、PRACTICAL CONSIDERATIONS FOR AUTOMATED DECISION MAKING Lynn Parker Dupree,Partner,Finnegan,Henderson,Farabow,Garrett,and Dunner LLPNicholas Godlove,Global Privacy Counsel,Yum!BrandsEmely Thompson,Privacy and Information Security Counsel,State FarmWELCOME AND INTRODUCTIONSWhat is Automated Decision-M
2、aking?The process of making a decision by technological means without human involvement.Regulatory LandscapeUS State LawColorado ConnecticutVirginia CaliforniaWatch out for:City/State Specific LawsNew York City Local Law 144(employment)Portland City Ordinance 190114(facial recognitionIllinois Biomet
3、ric Information Privacy ActFTC v.Rite Aid Corp.-AllegationsRite Aid contracted with two companies to create a“person of interest”database.The database generated thousands of false positive matches.Rite Aid was subject to a 2010 consent order to maintain a comprehensive information security program a
4、t the time this initiative launched.FTC v.Rite Aid Corp.Enforcement Action AllegationsRite Aid failed to:Consider and mitigate potential risks to consumers from misidentifying them,including heightened risks to certain consumers because of their race or gender.Rite Aids facial recognition technology
5、 was more likely to generate false positives in stores located in plurality-Black and Asian communities.Test,assess,measure,document,or inquire about the accuracy of its facial recognition technology before deploying it,including failing to seek any information from either vendor it used to provide
6、the facial recognition technology about the extent to which the technology had been tested for accuracy;Prevent the use of low-quality images in connection with its facial recognition technology,increasing the likelihood of false-positive match alerts;Regularly monitor or test the accuracy of the te