An Emerging Technology Charter for London

When trialling and deploying emerging technologies, we aspire to work in the open wherever we can, sharing our thinking as we progress and work collaboratively with city authorities, including measures like:

• setting out in plain English to the public what the technology is, what it can do, why it is being used and, where appropriate, the legal and ethical basis for doing so. For example, TfL’s approach to collecting anonymised wi-fi data on London Underground

• communicating with local communities who might be affected by the technology, providing an easy way for the community to talk back to you and make changes

• publishing Data Protection Impact Assessments (DPIAs) on London's Privacy Register. A DPIA is a legal obligation to identify and minimise the risks of a project when it's likely to result in a high risk to individuals. Following the completion of your DPIA, we recommend you fill in a submission form, and request it to be published on the London Privacy Register on the London Datastore to promote public transparency and good practice.

• if a trial or pilot, giving regular updates to the commissioning body pre- and post-trial, including reflecting on the successes and challenges of any trial undertaken, for example as advised in TfL's guidance for Connected Autonomous Vehicle trials

• being clear about any additional functionality of new technology (especially if software-as-a-service) even if not used, and the circumstances and process by which that functionality could be put to use in the future.

Together with other leading digital cities in Europe and North America, London strongly believes that human rights principles should be incorporated by design into digital platforms which serve our city. The Charter suggests:

• adopting user-centre design princinples when developing and testing new technologies. This approach focuses on the needs of users at every stage of the design of new technology, and ensuring feedback is continually appraised and used for improvement

• hiring a more diverse and inclusive workforce and benefit from the lived experience of Londoners in your team, for example by joining City Hall's Technology Design Lab

• for public bodies, setting out how the technology or service meets the Public Sector Equality Duty for example:

  • consideration of the impact the technology may have on any existing services - if the new technology replaces an existing service then provision should be made for continued access to this service by people who do not have either the required device or skills to access it by the new route

  • explicitly considering any potential bias, notably but not exclusively racial bias arising from the data, system or decision

  • if certain groups are excluded from the benefit of new technologies, the technology should have a clear reason why it does not serve these groups.

• addressing the value, need or harm addressed by the new technology by using techniques to consider the potential consequences of the product or service on people, communities and the planet

• human rights issues can be considered in procurements across the public sector, according to government guidance. Bidders may be excluded from public contracts where they have violated certain environmental, social and labour laws, including on human rights matters.

London requires safe, secure and useful ways of using and sharing data which build trust among our partners and citizens. Living the spirit, not just the letter of UK data protection (UK GDPR) means seeing the requirements as deep ethical obligations as well:

• considering not just to how the data is used, but what human processes or decisions are subsequently based on it, for example using established data ethics tools, see resources

• ensuring privacy by design from the design stage through the lifecycle of new products and services:

  • making it easy for a user who does not wish for their data to be used in a particular way, or wishes to opt-out at a later stage, to do so and be clear about how long the data will be held for

  • ensuring that the collection of any personal data is justified and mindful that even if you don’t mean to identify people in your smart places projects, if you can distinguish them from other individuals it will trigger data protection law

  • maintaining high quality data standards with complementary metadata so it is clear where the data comes from and how it was collected.

• use of biometric data: the UK Information Commissioner’s Office (ICO) sets a very high bar for use of biometric data such as Live Facial Recognition Technologies, in public spaces by non-law-enforcement bodies: including consideration of bias, the potential impacts on rights and freedoms of citizens, and demonstrating that other less intrusive measures cannot reasonably achieve the same purpose. If these technologies cannot meet the tests set out by the ICO then they should not be deployed in London

• compliance with the latest connected places cyber-security guidance issued by the National Cyber Security Centre and the relevant steps in the UK Government’s Technology Code of Practice. Ensure that there are plans to maintain cyber-security of the technology and data during its entire lifetime.

Emerging technologies have a physical, not just a virtual footprint. London wants new technologies to be as sustainable as possible, contribute to the Mayor’s goal to be a net zero carbon city by 2030, and sympathetic to the public spaces that make our city great:

• follow the Business Climate Guidance in the counting for the entire life-cycle impact of the technology, including its design, use and eventual retirement. This may include de-carbonising production, considering energy use in data processing and an end-of-life plan for hardware
• through our planning policies we encourage the use of smart technologies to gather data on the performance of the built and natural environment, including water and energy consumption, waste, air quality, noise and congestion. Non-personal data of this kind in public places can be shared with the London Datastore to ensure pan-London insights can be gained
• over many decades, London has evolved, resulting in an extraordinary web of distinctive residential streets, squares, markets, parks, offices, and industrial and creative spaces. Consideration should be given to the impact on neighborhood amenity of any hardware installed in the public realm, and having a plan for its removal and responsible disposal when it reaches the end of its useful life.