Standing Committee on Industry and Technology,

Given the recent significant changes to Part 3 of the bill, the Artificial Intelligence and Data Act (AIDA) in particular, we are reaching out to share additional feedback on the amendments proposed by Minister Champagne and reiterate the importance of consistent dialogue between INDU, the Government of Canada and industry members at this decisive stage in the legislative process. [...] In addition to broad concerns with the definition of high-impact provided in AIDA amendments, we would like to note the following issues with the proposed classes: Use of AI in the Provision of Services: Use of the term “services” to describe this proposed class of AI systems is incredibly broad and in need of clarification. [...] Recommendation: Clarify that the proposed class of “high-impact” AI systems related to the provision of services to an individual, including whether to provide services, determining the type and cost of services, and the prioritization of services to be provided, is in reference to government services. [...] 9 This exception should include the obligation on persons responsible under the Act to disclose prescribed information; as well as the right to disclose information by i) the Minister or Commissioner to others and ii) the right to publish information by the Minister or the Commissioner. [...] To strike a better balance between the intent of AIDA to enhance the transparent use of AI systems with the need to protect organizations’ confidential and sensitive information, we recommend that a general account of AI systems, including high-impact and general-purpose AI systems, similar to the provisions outlined in CPPA’s s.62 (2), would provide an appropriate level of detail to the public wi.