In comments to Customs and Border Protection, EPIC recommended the adoption of the Universal Guidelines for Artificial Intelligence for a new boded controls system, the "21st Century Customs Framework." EPIC , stressed the need for transparency, accountability, and fairness in automated decisionmaking. EPIC explained “Although CBP claims that risk scores are only used on cargo,” the "impact falls on individuals.” EPIC previously submitted comments to the agency regarding the Automated Targeting System and the Intelligence Records System. Through FOIA, EPIC has also obtained information on the agency’s data systems, including the Analytical Framework for Intelligence, which assigns “risk assessments” to travelers, including U.S. citizens.
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