Sagsnr. 2021 - 1797 Doknr. 397748 Dato 03-03-2021

Comments on the outline for a General Comment on the right of persons with disabilities to work and employment (Article 27 of the Convention on the Rights of Persons with Disabilities)

Submission of the Danish Government

The Danish Government welcomes this opportunity to submit comments on the outline for a General Comment on the right of persons with disabilities to work and employment. The Danish Government commends the Committee for its initiative in drafting a General Comment on this subject and considers that the General Comment will provide valuable guidance to State Parties in the implementation of their obligations under the Convention.

The Danish Government would first like to underline the importance that it attaches to the Convention, and reaffirm its commitment to comply with Denmark's obligations under the Convention.

On the right to work and employment and the issue of non-discrimination in relation to artificial intelligence, the Danish Government would like to draw the attention of the Committee to the Danish National Strategy for Artificial Intelligence which was launched in 2019. The strategy focuses on how Denmark can be a front-runner in responsible development and use of artificial intelligence.

One of the goals of the Danish Government is that ethical principles should be incorporated in the development and use of artificial intelligence to secure respect for individuals and their rights and for democracy. One of the principles concerns equality and justice: “Artificial intelligence should not reproduce prejudices that marginalize specific population groups. Focus on preventing unwanted bias and promoting designs that avoid classification discriminating on ethnicity, sexuality and gender, for example. Demographic and professional diversity should be guiding parameters in working with artificial intelligence.”

The target audience for the ethical principles are authorities, businesses, research institutions etc. which are working on artificial intelligence. The principles reflect Danish values and have been prepared on the basis of the recommendations from the Expert Group on Data Ethics set up under the Danish Disruption Council, and the draft EU ethical principles and guidelines for artificial intelligence.

In addition to the principle of equality and justice, the six principles deal with:

1. Self-determination

2. Dignity

3. Responsibility

4. Explainability

5. Equality and justice

6. Development

The Danish government has also established a Data Ethics Council in 2019. The tasks of the council are to make recommendations and support broad public debate on issues regarding data ethics, including artificial intelligence. The council monitors technological development and helps to ensure that ethical issues are discussed in order to ensure that advantages of data usage are achieved in an ethically appropriate manner.

Denmark reiterates its firm support for the work of the Committee and avails itself of this opportunity to renew to the Committee the assurances of its highest consideration.