EPIC, CDT Urge HUD to Abandon Proposed AI Tool That Would Use Sensitive Data

On Wednesday, EPIC and the Center for Democracy & Technology submitted comments to the Department of Housing and Urban Development in response to its recent Notice of Intent to modify its System of Records. 

The proposed changes include collecting new categories of personally identifiable information and introducing AI features that “would use existing case/service request information and the organization’s internal knowledge base to generate draft case summaries and suggested email responses.” 

The collection of new categories of data and use of AI could impact every existing use of data in the system. Despite the potentially serious consequences of these proposed modifications, HUD’s Notice lacks significant details about system accuracy, fitness and safety, security protocols to protect sensitive information, and accountability mechanisms for individuals whose information is processed by the AI system.  

To make matters worse, the Notice suggests that these practices have already been taking place prior to its publication. These deficiencies violate the Privacy Act and EPIC and CDT urge HUD to roll back these changes. 

EPIC routinely advocates for responsible government data use, minimizing data collection, and transparent AI policies and regulations. We’ve submitted comments on these issues to the Department of Health and Human Services, the Department of Housing and Urban Development, and the White House Office of Science and Technology Policy, among others.