Table 3 Legal support and regulatory mechanism in data ethics framework of countries and supranational alliances.
Rank | C/SA | Legal support | Regulatory mechanism |
|---|---|---|---|
1 | United Kingdom | UK’s framework complies with the UK GDPR and DPA 2018 in personal data processing, and ensures that analysis and automated decision-making do not result in discriminatory outcomes as defined by the Equality Act. | UK requires data users to develop a comprehensive plan for responsible data use, alongside assessment programs and accountability mechanisms for oversight. |
2 | United States | American framework draws upon numerous legal standards across various industry sectors. | / |
3 | Germany | German framework references GDPR data subject rights, emphasizes strengthening existing legal tools for data ethics regulation, and suggests cautious adjustments to conflicting parts of current legal frameworks. | Germany has developed a “Critical Pyramid for the Use of Algorithmic Systems and a Risk-Adaptive Regulatory System,” categorizing application systems into five levels of risk and proposing corresponding regulatory measures, along with specific recommendations for data ethics oversight. |
4 | Switzerland | Participating institutions have to comply with Swiss law, including but not limited to the FADP, the HGTA, and the HRA. | Switzerland provides specific action guidelines for accountability mechanisms, including the transparency and auditability of data processing personnel and procedures, appropriate monitoring, performance evaluation, and regular auditing of data security measures, and assessment of the capabilities of institutions managing human biological materials. |
5 | European Union | Trustworthy AI requires legality, ethics, and robustness, with legality as the priority. Ethical principles are based on fundamental rights outlined in EU treaties, the EU Charter, and international human rights law. | EU promotes accountability mechanisms to hold responsible parties accountable for outcomes throughout the development, deployment, and use of AI systems. A checklist has also been developed to assess AI trustworthiness. |
6 | UNESCO | UNESCO’s framework follows the spirit of the United Nations Charter, the Universal Declaration of Human Rights, and the United Nations Declaration on the Right to Development. | UNESCO proposes the establishment of appropriate oversight, impact assessment, auditing, and due diligence mechanisms to ensure accountability for AI systems and their impacts throughout the entire lifecycle. |
