Aleksandr Tiulkanov has advised businesses on legal and compliance matters since 2003 and has focused on IT law and digital policy since 2015. He has previously been a Special Adviser on Digital Development at the Council of Europe; as well as Senior Manager for Technology, Media and Telecoms at Deloitte Legal. Aleksandr is also a Member of the AFNOR CN IA (French Commission on AI Standardisation), as well as a Member of the CEN-CENELEC JTC 21 (Artificial Intelligence), and a PECB Certified ISO/IEC 42001 Lead Implementer. He also holds an LL.M. in Innovation, Technology and the Law, University of Edinburgh (2018) and has been listed in “Best Lawyers in Information Technology Law (2020)” References: Aleksandr Tiulkanov on LinkedIn Engagements and training by Aleksandr Tiulkanov Preparing for the EU AI Act, a 4-week course by Aleksandr Tiulkanov (code for a 10% discount: MOPPTL2) For how the Article 50 disclosure duties apply to chatbots, see this guide on “AI Act duties for chatbots”. Paragraphs 1-4 of Article 50 of the EU AI Act: Transparency obligations for providers and deployers of certain AI systems * Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI systems, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use. This obligation shall not apply to AI systems authorised by law to detect, prevent, investigate or prosecute criminal offences, subject to appropriate safeguards for the rights and freedoms of third parties, unless those systems are available for the public to report a criminal offence. * Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, shall ensure that the outputs of the AI systems are marked in a machine-readable format and detectable as artificially generated or manipulated. Providers shall ensure their technical solutions are effective, interoperable, robust and reliable as far as this is technically feasible, taking into account the specificities and limitations of various types of content, the costs of implementation and the generally acknowledged state of the art, as may be reflected in relevant technical standards. This obligation shall not apply to the extent the AI systems perform an assistive function for standard editing or do not substantially alter the input data provided by the deployer or the semantics thereof, or where authorised by law to detect, prevent, investigate or prosecute criminal offences. * Deployers of an emotion recognition system or a biometric categorisation system shall inform the natural persons exposed thereto of the operation of the system, and shall process the personal data in accordance with Regulations (EU) 2016/679 and (EU) 2018/1725 and Directive (EU) 2016/680, as applicable. This obligation shall not apply to AI systems used for biometric categorisation and emotion recognition, which are permitted by law to detect, prevent or investigate criminal offences, subject to appropriate safeguards for the rights and freedoms of third parties, and in accordance with Union law. * Deployers of an AI system that generates or manipulates image, audio or video content constituting a deep fake, shall disclose that the content has been artificially generated or manipulated. This obligation shall not apply where the use is authorised by law to detect, prevent, investigate or prosecute criminal offence. Where the content forms part of an evidently artistic, creative, satirical, fictional or analogous work or programme, the transparency obligations set out in this paragraph are limited to disclosure of the existence of such generated or manipulated content in an appropriate manner that does not hamper the display or enjoyment of the work. Deployers of an AI system that generates or manipulates text which is published with the purpose of informing the public on matters of public interest shall disclose that the text has been artificially generated or manipulated. This obligation shall not apply where the use is authorised by law to detect, prevent, investigate or prosecute criminal offences or where the AI-generated content has undergone a process of human review or editorial control and where a natural or legal person holds editorial responsibility for the publication of the content. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.mastersofprivacy.com/subscribe
