The way in which Father Christmas and his elves have operated over hundreds of years has experienced minimal change.
Much like the way he has had to adapt to deliver gifts to children in homes without a chimney, there is a risk that unless he can apply the same adjustments to his operating model to thrive in a modern digital world, the magic of Father Christmas will become myth.
How could Father Christmas embrace digital transformation?
He traditionally gathers only offline information about children’s behaviour to determine whether they belong on the “naughty” or “nice” list. Yet, with 53% of children in the UK owning a mobile phone by the age of seven, and 90% by 11, extending the scope to also cover their online behaviour would enable, if implemented with appropriate controls, a much richer and accurate understanding of each child. New emerging technologies, including AI, can enhance this in a number of different ways. However, for this type of processing to be lawful, it will need to comply with the privacy laws in each territory the children reside. For instance, the GDPR requires additional conditions to be met for high-risk processing activities and permits automated decision making and profiling to be carried out either where the data controller is authorised by domestic law, has the individuals’ consent or requires it to fulfil a contract with them.
What actions would Father Christmas need to take to get AI right?
In order to set up a new AI infrastructure, Father Christmas and his helpers will need to take specific steps to identify, monitor and mitigate the risks such processing can have on the children and their families. This includes:
- Conducting an AIA (algorithm impact assessment) to address areas of concern. For example, the algorithmic bias that influences the decision to include more children from poorer households on Father Christmas’ ‘naughty’ list.
- Carrying out a DPIA to identify potential risks and implement measures to mitigate these sufficiently, such as ensuring extra controls are in place to restrict access to the location of children in temporary accommodation such as shelters and refugee camps.
- Informing the children and others on the processing in an accessible way so that they (or their guardian) can make informed decisions on how their information is handled.
- Ensuring the relevant elves receive specialist training on the technology and how it works to ensure standardisation and prevent the likelihood of human/elf error inciting a data breach.
It is important to note that each jurisdiction will set its own requirements on how AI is safely and lawfully administered.
On the final point, it is custom in some cultures that children on Father Christmas’ naughty list are given coal for Christmas. We anticipate this too will gradually be phased out over time as he looks to reduce his carbon footprint.