KPMG's submission to the Department of Industry, Science and Resources on Safe and responsible AI in Australia.
As a leading professional services firm, KPMG Australia (KPMG) is committed to meeting the requirements of all our stakeholders – not only the organisations we audit and advise, but also employees, governments, regulators – and the wider community. We strive to contribute in a positive way to the debate that is shaping the Australian economy and we welcome the opportunity to provide a submission to the Department of Industry, Science and Resources Safe and responsible AI in Australia discussion paper (the discussion paper).

This submission builds on KPMG’s previous engagement in the safe and responsible development of AI in Australia and globally. KPMG has provided a number of submissions to various forums on this topic, including on Automated Decision Making and AI regulation in July 2022, An AI Action Plan for all Australians in December 2020, the Australian Data Strategy in July 2022, and Human Rights and Technology in 2020 and Beyond in March 2020. KPMG published a report with the AIIA in March 2023, Navigating AI: analysis and guidance on use and adoption, which examines the global and domestic regulatory landscape in the Artificial Intelligence space.

KPMG is an early and active user of AI, having recently expanded our partnership with Microsoft to streamline the deployment of AI in our back-office functions and consider its use across tax, audit and advisory work1. KPMG is also developing a people-centred approach to AI that will apply to the design and deployment of AI within the firm.

The successful adoption of responsible AI needs to be assisted by addressing the public’s current lack of trust in AI by ensuring the right mix of policy settings, regulations and laws to ensure AI use is safe. KPMG and the University of Queensland’s research has found that only two in five people believe current regulations, laws and safeguards are sufficient to make AI use safe. Without appropriate legal and regulatory frameworks, a lack of trust in AI will persist, meaning that it is likely that its full potential will not be realised.

In this submission, KPMG recommends a people-centred approach to AI that prioritises regulatory action on the human rights impact and potential harms of specific types of data used in AI solutions, data protection and integrity and ensuring the definition of personal information can meet the diverse types of data underpinning AI solutions. While in this submission we have focused on a people-centred approach to AI, we acknowledge there are various other impacts, such as environmental considerations, that will also need to be addressed. KPMG supports harmonising overlapping regulatory frameworks across Australia and ensuring greater consistency with international regulatory frameworks to reduce administrative burden and assist technology exporters.

The submission outlines 16 recommendations at section one and directly addresses the consultation questions at section two. If you would like to discuss the contents of this submission further, please do not hesitate to reach out. KPMG looks forward to continuing engagement with the Australian Government as it develops a safe and responsible framework for AI in Australia.

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