The Global Network Initiative (GNI) appreciates the opportunity to submit evidence to the UK Parliament’s Joint Committee on Human Rights as part of its inquiry on Human Rights and the Regulation of Artificial Intelligence.
GNI welcomes the Committee’s decision to frame this inquiry through a human rights lens, which it sees as essential for effective and legitimate AI governance. The submission outlines how grounding AI regulation in international human rights law — including rights to privacy, non-discrimination, due process, and access to remedy — can help build public trust and safeguard fundamental freedoms.
While existing UK laws such as the Data Protection Act 2018 and the Equality Act 2010 already apply to AI in some contexts, these frameworks were not designed with advanced AI systems in mind. The UK must ensure that the development of any new regulations or institutions remain consistent with international human rights obligations and in line with the approach that has been pursued in the setting of the UN AI governance mechanisms, and the commitments in the Sustainable Development Goals, the Pact for the Future and the Global Digital Compact.
The Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), the European Convention on Human Rights (ECHR), the UN Guiding Principles on Business and Human Rights (UNGPs), and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines) provide a well-established, globally recognised foundation for aligning technological innovation with societal values. In addition, the guidance coming from the UN General Assembly and the Human Rights Council – particularly resolutions such as Seizing the Opportunities of Safe, Secure and Trustworthy Artificial Intelligence Systems for Sustainable Development (A/RES/78/265), the Right to Privacy in the Digital Age (A/RES/79/175), New and Emerging Technologies and the Enjoyment of Human Rights on the Internet (A/HRC/RES/47/23) – along with the work of the Office of the High Commissioner for Human Rights (OHCHR) and the Human Rights Council’s Special Procedures, provides critical direction for ensuring that digital and AI technologies are developed and deployed in ways that uphold human rights.
Ofcom’s role under the Online Safety Act exemplifies how statutory duties, codes of practice, and enforcement authority can be structured in a dynamic and technically intricate field. However, concerns persist regarding whether Ofcom possesses sufficient capacity – and any future AI‑focused regulator would likewise demand substantial expertise and resources to be effective. The Act’s requirement for Human Rights Impact Assessments for each proposed mitigation is a commendable practice that the UK’s AI Governance Framework could adopt, along with the emphasis on coordination among multiple regulators.
GNI calls for human rights due diligence, transparency and accountability across the AI lifecycle, effective redress mechanisms, and inclusive, multistakeholder participation in regulatory design. GNI looks forward to supporting the Committee’s work and sharing insights from its diverse, global membership.
About GNI
The Global Network Initiative (GNI) is a multistakeholder organisation of leading technology companies, civil society groups, academics, and investors working to protect and advance freedom of expression and privacy rights in the global technology sector. GNI promotes rights-based expectations for responsible business conduct, facilitates cross-sector learning, and advocates for regulatory frameworks grounded in international human rights law. With members operating across diverse jurisdictions, GNI brings legal, technical, and practical expertise to emerging issues such as AI governance. It has contributed to the development of “online safety” laws in several countries through its human rights-based policy analysis, including its Content Regulation & Human Rights Policy Brief. GNI’s multistakeholder AI Working Group is also developing a Policy Brief on Government Interventions in AI, analyzing such efforts through a human rights lens.