1) AIAct “the fundamental rights impact assessment referred to in paragraph1 shall be conducted in conjunction with the data protection impact assessment. The data protection impact assessment shall be published as an addendum.”
2) Article 29a lists some criteria for the FRIA (but see also Article 7).
I agree with this outcome that looks beyond data protection by properly placing #dataprotection in the broader context of fundamental rights and ending its long-standing substitute role due to the absence of more comprehensive legal answers.
Some key points for FRIA: 1) there is no overall impact on fundamental rights, each right must be considered separately
2) the assessment is necessarily context-based
3) this is an expert evaluation exercise
4) clear matrices for this assessment must be outlined consistent with risk theory.
I have some doubts about a broad model that includes democracy (see Art. 9.2.a), as the notion of democracy and its various expressions make impact assessment methodologically difficult, even more so as it is hard to assess the level of democracy itself papers.ssrn.com/sol3/papers.cf…
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