Instilling Values: Oversight & Error

September 20, 2023

Written by Alex Lawrence

“Security by design is already problematic,” Paul Timmers commented. “Ethics by design is a very interesting concept.”

Timmers is an academic with roles across Europe, building on a long career within the European Commission. 6GWorld had a conversation recently with Timmers and Georg Serentschy, former head of the EU regulators’ forum BEREC, to explore whether and how it would be possible to ensure that 6G can deliver as the beneficial force in societies that governments want.

While we think of technologies as value-neutral, is that inevitable? Would it be possible to design ethics into a system or technology?  Timmers pointed to the sphere of AI, where exactly this challenge is being addressed, given the variety of impacts it can have, “Not only on personal data, but also on autonomy, on fairness, on discrimination, and ultimately also on things like national security.”

When we’re looking at AI ethics, Timmers identified a number of different levels which need to be addressed. 

–             The level of individual products. “Can you have design guidelines that can be exercised at the software and hardware level? There’s some progress; there are things appearing, tools, value design templates and those kinds of things. It’s still incomplete, but at least something is appearing.”

–             The level of oversight. “Do you have an organisation that actually watches the way you design, that can be held accountable, that does proper auditing? There’s also some progress in that. Gradually something is appearing, but we are not yet at the level of an ISO certification.”

–             The third level, developing global standards or alignment, is the big challenge, Timmers notes, describing this as “really geopolitics.” An ethical stance would begin to involve, for example, respect for human rights.

“An organisation like ISO may not want to burn its fingers on a thing like human rights. It’s supposed to be an international organisation, and certainly the views on human rights are a little bit different across the world.”

The outcome of this is that, because there are differences in the ethical positions of different cultures, countries and governments, ethics-by-design regionalisation might be inevitable. That would in all likelihood filter from regional standards down to the guidelines and tools being used in different parts of the world. 

Hang on, though, is that the end of the story? When the telecoms industry is so keen to ensure global standards in technology, should we just give up on any globally-aligned ethical positions? Certainly there are differences in priorities, but is there no commonality which can be used as a basis for ethically-designed telecoms systems?

“That sounds quite logical,” Timmers conceded, “but I am not technically deep enough into telecom architecture to know whether that’s also feasible.”

Oversight and ‘The Right Conclusions’

If there are concerns over what kind of international organisation would be able to create a global alignment on ethics – whether AI or 6G – this also applies within individual nations. Who would be the right people to oversee a country’s development and application of ethics by design? The regulator? Georg Serentschy, as a former regulator himself and convenor of regulators across Europe, has a definite view of this.

“The vast majority of regulators are not prepared for dealing with these kinds of questions,” he stated. “They have real difficulties in in adopting and subscribing to new things, looking at new challenges.”

By way of an example, Serentschy put forward the point about network resilience, something much closer to standard regulatory agendas but which also feeds into many countries’ demands for a robust and reliable 6G service.  

“Resilience of networks heavily depends on the amount of redundant infrastructure and that goes completely in the opposite direction of cost saving. There is a strong demand to combine networks or to share network elements and that runs completely against resilience indirectly because the redundancy is reduced,” Serentschy noted.

“The Icelandic Regulator has understood that this is a market failure and demanded that operators think more in terms of resilience. I would say 95% of all the European regulators have not picked up on this issue.”

This sounds damning but there is a good reason why this should be so, and that is because of the boundaries of regulators’ perspectives and arguments.

“This is an interesting example where the classical boundary between competition policy and market access regulation has to be rethought,” Serentschy pointed out.

“It is driven from a completely different argument than you would traditionally have in competition policy, which would be about consumer benefits, fair treatment, those kinds of things. This is a resilience argument which is society-wide.”

Regulators are, of course, typically bound by their remit and limited by what they are allowed to do. As a result, they may feel that they are not constituted to take on any responsibility to deliver or oversee an ethical 6G, even if they consider the subject important. If not a regulator, though, then who? Policymakers?

“It is, of course, a hard thing for policymakers to really look at things from various disciplines,” Timmers pointed out,

“But partially you might of course also think they would feel uncomfortable touching those topics. It is uncomfortable stuff.”

Bad Medicine

What can we learn from the way that ethics is administered in other areas? While it is a new thing in telecoms and AI, in the biotech and healthcare industry an ethical outlook goes back centuries. While there definitely is regulation in that industry, there is also consensus, Timmers noted.

“Do you remember this case of the Chinese guy who modified the DNA of two girls so that they would be resistant against HIV, and everybody said, “Well, but now you’re tinkering with the human genome, you shouldn’t do that”? It was apparently international pressure that triggered the Chinese government then to take this a bit more seriously and he went to jail.”

In this case there was no formal world-spanning regulatory framework in place. However, most countries do have ethics commissions set up by governments which can advise on what might be seen as ethical research or policies. In this case it failed to function but a global professional community was able to police what was happening and influence the Chinese government to step in. This kind of crowdsourced normative function is something which could, in principle, be developed within the telecoms and tech industry too.

“How much sunlight should expose what’s happening in 6G to ensure that we get ethics by design? Sunlight in the sense of being the disinfectant,” Timmers asked.

Whether sunlight alone will be enough to propel an ethical 6G is doubtful, though it might act as a failsafe. It would require a good deal of transparency about technologies and systems, which open projects can provide; but it would also require people who are able and motivated to think through any ethical ramifications of the technologies rather than, for example, waving that off during the R&D phase as something for the applications developers or regulators to worry about.

The analogy with biotech also suggests that governments should be setting up ethical oversight advisory bodies with a combination of expertise that ranges across ethical and civil concerns as well as telecoms technology.

At the same time, there is a clear lack of appetite from within the telecoms community for governments taking a role in setting the direction of travel for technology implementations and selection. If not them, though, who? Is there a role for industry bodies such as ETNO or GSMA; for standards development organisations to expand their remit? Or for the ITU to develop new functionality?

Whatever the case may be, with less than a year before the standards process commences this seems like a good time for alignment on how to design in the kinds of outcomes that governments globally, on behalf of their societies, are demanding from 6G; and perhaps more importantly to curb developments which would contradict those societal ends, such as impairing sovereignty or strategic autonomy.  

“Quite a while ago I wrote a paper saying that if we don’t fix 5G security, we will not be able to get it right in in 6G,” Timmers observed.

“The outcome in terms of national security and sovereignty that 4G delivered was not acceptable for at least, let’s say, the Americans and a number of others. And so we got this debate about 5G security where certain people don’t buy from certain suppliers. In my analysis, part of that is actually because the relationship between governments and industry did not work. Industry did its thing and technology did its thing separate from those discussions.”

In this case, a disjunction between government requirements – whether implicit or not – and the commercial and technological impetus behind the telecoms industry had huge effects on the industry in several countries. Re-investing in existing infrastructure has strained telecoms operators, while limitations on major vendors has spurred new dynamics in the market, realigning major OEMS and giving open networks bodies extra stimulus.

Can we be sure that we have learnt the lesson? It’s not clear we have, as Timmers pointed out.

“I must say I was a little bit disappointed looking into some 6G architecture papers that have been written and published, that didn’t really address national security and sovereignty or security in a proper way. So I’m not so optimistic that they will get it right this time.”

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