Launch of London’s Emerging Tech Charter

A set of practical and ethical guidelines for smart city emerging technology was launched today in London, Chief Digital Officer for London Theo Blackwell sets out why…

As part of London Tech Week The Mayor of London is launching the Emerging Technology Charter for London — which lays out a clear pathway for the ethical use of future technologies in city.

London’s Emerging Technology Charter, the first of its kind in any UK city, is a set of practical and ethical guidelines focussed on openness, digital rights, use of data and sustainability of technology which will:

• Set common expectations to tech buyers and makers to innovate successfully.
• Give Londoners and their elected representatives a clear framework to ask questions about the technologies proposed or deployed in London.
• Establish enhanced transparency for Londoners on products and services that data protection law considers potentially high risk to privacy.

The Charter will cover technology such as driverless cars, facial recognition software, drones, sensor networks, robotics, mobility services, augmented and virtual reality, and automated and algorithmic decision-making.

The Charter is voluntary, but local government and public services, makers, innovators, technologists, elected representatives and interested Londoners are all encouraged to adopt it to improve how technology is implemented in the capital.

The Charter was developed in the open over 2020/1 following consultation with subject experts drawn from the Smart London Board, innovators, Londoners and their elected representatives. This found strong appetite for public service innovation with new technologies and backing for the concept of a Charter.

What do we mean by emerging technologies?

A Digital Catapult report (2020) commissioned by the Mayor of London identified the capital as a global hub for the research, development and innovation of 5G, internet of things (IoT) and artificial intelligence (AI). This new digital infrastructure makes internet speeds faster, provides vast amounts of real-time data and allows the processing of data quickly and support a new generation of services and applications.

In coming years these future technologies and services will use this next generation connectivity, faster access to and processing of data and artificial intelligence to build new products and applications that can meet the needs of users. The types of emerging technologies we are beginning to see in cities include the use augmented reality, increased use of autonomous vehicles, remotely-operated machinery, smarter logistics, environmental and biometric monitoring.

Many capabilities and uses will be in the smart cities sector, a field which applies new technologies to improve the operations of city government and others, and ultimately the quality of life for citizens. Across all sectors we anticipate an acceleration in the availability of networks of sensors, cameras, drones, robotics, mobility services, augmented and virtual reality and automated and algorithmic decision-making. Over the next decade take-up is also expected to rise rapidly as capability grows, costs lower and even more uses are developed.

Policy background

The 2021 Manifesto committed to “create a new Emerging Technologies Charter for London to guide the deployment of sensors and services arising from 5G and artificial intelligence and make their use transparent to the public.” The GLA’s planning policies 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. In the new London Plan, adopted in 2021, the GLA pledged to issue further guidance on these technologies.

London is also becoming more digitally connected. TfL’s roll-out of underground 4G mobile services has seen hundreds of kilometres of fibre laid in tunnels, creating a new fibre backbone for London using public sector-owned surface assets, like buildings and ducting, to support last mile connectivity by private providers. The effects will go beyond transport, helping businesses get higher speed connectivity and 5G, and support the capital harness smart city technology to improve urban life.

London’s public bodies already have a track record of deploying data-enabled technologies for specific purposes, from the Congestion Charge (2003) onwards to the recent deployment and trials of air quality sensor networks, mobility services, applications to improve administration and decision-making, or live facial recognition cameras for community safety. The global technology market is also presenting owners and manager of the city’s privately-owned public realm with the capabilities to understand footfall and occupancy, opportunities for digital advertising and security.

The GLA Group has growing body of insight and evidence relating to data ethics and Londoners’ views on the use of technology and data in the capital. This includes:

• Polling on Londoners’ views of data
• a Citizens’ Summit with NHS One London on sharing health data
• the incorporation of the findings Metropolitan Police’s (MPS) Ethics Panel on Live Facial Recognition
• Piloting EU-funded smart city initiatives in Greenwich
• Cleantech and other sustainability-focused smart technologies at the Olympic Park
• TfL’s pilot of the use of Wifi data on the underground and subsequent deployment
• Connected Autonomous Vehicle, demand responsive bus and e-scooter trails as and open innovation with AI companies

The Charter also follows a recommendation made to the GLA by the Digital Catapult that “The Mayor of London should develop an approach to formalise, structure and inform discussions around the adoption and deployment of advanced digital technologies in London; ensuring that new technology aligns with city principles, that there is a clear and consistent ask of the tech sector by government, and that a diverse range of voices are heard.”

More broadly, the Charter follows the example set by other cities, notably San Francisco and Boston, on creating consistent frameworks to guide conversations between cities and innovators on when and how to deploy new technologies. The Charter also draws from the Cities Coalition for Digital Rights Declaration, of which London was an early signatory.

Purpose

The rapid pace and range of technological change mean that lessons from current deployments and, as highlighted in the government consultation Data: a new direction (September 2021), important guidance to buyers, makers and citizens currently resides across many different public, research and civil society bodies.

The uncertainty of how this fits together in practice can undermine public trust if Londoners do not have the necessary information on why and how new technologies relying on data are chosen, rolled out and operate. It can also present a barrier to adoption between innovators and buyers if expectations are unclear during procurement. By setting out the Charter’s principles in this way we aim to foster a trustworthy environment for innovation to flourish, and to do so responsibly for the benefit of Londoners.

Operation

The Charter sets four principles for implementing technology in London. Drafted by the Chief Digital Officer for London and advised by working group drawn from the Smart London Board, these principles are drawn from London’s experience deploying new technologies and the views of innovators and those of Londoners themselves and their elected representatives.

1. Be open
2. Respect diversity
3. Be trustworthy with peoples’ data
4. Be sustainable

The principles are expressed through a series of suggested measures and examples. These will be added to over time where we see good practice or it is suggested to us. Resources from government departments and other bodies are also consolidated in the Charter.

The Charter is an agile governance framework for discussing the deployment of smart city emerging technologies. This allows for flexibility and change as technologies, legislation and guidance develops, within the envelope of the four principles now considered as part of the reputational risk management undertaken by innovators and buyers.

All principles should apply to all technologies, but some measures may not — so this acts as a guide to structure and inform discussions around adoption. (Individual public bodies may also have their own procedures or ethics frameworks specific to their responsibilities or professions).

Specific measures: register of Data Protection Impact Assessments (DPIAs)

A key measure to promote transparency is the measure in Principle 1 creating a central registry of DPIAs. A Data Protection Impact Assessment (DPIA) is a process to help organisations identify and minimise the data protection risks of a project. Organisations must do a DPIA for processing that is likely to result in a high risk to individuals. It is also good practice to do a DPIA for any other major project which requires the processing of personal data.

The ICO guidance states that the DPIA must:

• describe the nature, scope, context and purposes of the processing;
• assess necessity, proportionality and compliance measures;
• identify and assess risks to individuals; and
• identify any additional measures to mitigate those risks.
• To assess the level of risk, you must consider both the likelihood and the severity of any impact on individuals. High risk could result from either a high probability of some harm, or a lower possibility of serious harm.

Some specified types of data processing require a DPIA, including automated decision-making, systematically monitoring a publicly accessible place on a large scale; large scale profiling and profiling, automated decision-making or special category data to help make decisions on someone’s access to a service, opportunity or benefit; and biometric data.

The publication of DPIAs is not required but seen as good practice. DPIAs on Live Facial Recognition Technologies (MPS) and the NHS COVID-19 App (NHS Digital) are examples where DPIA were published and open to scrutiny. The Charter’s recommendation takes this a step further by proposing to create an easy way to find all relevant and shareable DPIAs concerning smart technologies in London. This will make it easier for Londoners to access DPIAs, and for civil society or research bodies to examine them at scale.

The DPIA register also forms part of the GLA’s draft Public London Charter, linking the two sets of guidance.

Next steps

Following the publication of Version 4 of the Emerging Tech Charter for London several further steps will be undertaken by the Chief Digital Officer for London:

Public body leadership to adopt Charter principles and working with the London Office of Technology & Innovation to incorporate into their smart city playbooks.

Explore the creation of the Charter as a digital service, walking users through key principles and measures.

Creation of a service for the publication of DPIAs on the London Datastore.

Add further examples of good practice and useful guidance to the Charter where we see it.