The following migration-related policy recommendations are proposed for Frontex:
- Establishing information and communication plans aimed at regularly informing different target audiences about Frontex’s use of OSINT and AI technologies, including actions such as:
- Increasing the dissemination of information on how European borders are managed, the technologies, methods and procedures used, and the risks and consequences of all this
- Developing communication campaigns about the technological system used
- Constantly informing the public and stakeholders about processes and results
- Making it clear, both internally and externally to the organisation, how the new tools are used and managed.
- Defining protocols for the responsible use of OSINT and AI tools, identifying technical and ethical standards, including actions such as:
- Establishing an ethical monitoring system managed by external experts
- Adopting a code of conduct
- Communicating to stakeholders and the public about how ethical issues are managed
- Designing and implementing pilots to verify the ethical robustness of the system before it is used
- Coupling the new technologies with other technologies and information sources to prevent and reduce errors.
- Introducing procedures to check the quality of data and detect biases and errors
- Including professionals working in different languages to interact with migrants and refugees
- Reinforcing the staff with new specific professionals (e.g., psychologists, health experts, human rights experts, cultural mediators, gender experts)
- Introducing indicators and measurements able to rank the reliability of the data produced
- Introducing procedures to check the quality of data and detect biases and errors
- Involving independent professionals to assess the system
- Ensuring constant training of the staff
- Ensuring a regular updating of the technologies and methods
- Promoting a learning-by-doing process in using the new technologies to understand how to properly use them
- Using multiple information sources to verify the reliability of those used by the system
- Developing governance structures enabling stable cooperation with stakeholders for the sharing and exchange of information on migration, including actions such as, including actions such as:
- Constantly informing stakeholders about processes and results
- Establishing two-way communication channels that allow stakeholders to contribute to the development of the system by providing the information they gather during their activities
- Establishing forms of collaboration with stakeholders to identify solutions to prevent social and ethical risks
- Involving academic institutions to adopt standards in the governance of the system
- Creating an advisory board as a separate entity
- Ensuring constant training of the staff about communication and interaction with external actors
- Establishing protocols to allow access to the system from third parties
- Promoting a bottom-up participation process to design and manage the system
- Involving international organisations (especially UN agencies) to favour a fruitful interaction between national and European authorities and civil society
- Participate actively in the management of the CIPPMAA project by appointing one member to the CIPPMAA Steering Committee
To implement the above recommendations the following guidelines are provided:
- Transparency about FRONTEX’s role and actions is perforce dependant on the quality of its communication strategies and implementation of such strategies, hence the emphasis laid in these policy recommendations on the communications strategies relevant to AI tools and OSINT.
- FRONTEX should not design and implement by itself the protocols for the responsible use of OSINT and AI tools, including the identification of technical and ethical standards. It should do so in very close co-ordination with all parties concerned and especially LIBE, the EDPS, EASO, EUAA, civil society organisations, national border agencies, academic experts, industry etc. both within and outside CIPPMAA formal project management structures.
- Ownership for the outcomes of its implementation of legislative measure, communication strategies, protocols for the deployment of OSINT and AI tools, as well as further contributions to proper oversight functions should be further reinforced by FRONTEX appointing one of the permanent members of the CIPPMAA Steering Committee which member should also be responsible for liaising with and reporting to the FRONTEX top management including the Director as and when necessary or appropriate
