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On August 3, 2024, Dr. Bosun Tijani, Nigeria’s Minister of Communication, Innovation, and Digital Economy, released a draft of the ‘National Artificial Intelligence (AI) Strategy,’ inviting public feedback on its contents.
Clarity of Purpose
The 73-page document lacks a clear articulation of its purpose. The introduction fails to explicitly define the strategy’s goals. Although page 12 mentions that the strategy should align with national values and future goals, it does not clearly state its objectives or how resources will be allocated to achieve them. A national strategy document should provide a clear guide and outline how resources will be allocated to meet policy objectives. This clarity is currently missing, making the document less useful for stakeholders.
Insufficient Commitment to Privacy and Data Protection
Given the strategy’s focus on enhancing citizens’ welfare, a robust commitment to privacy and data protection is expected but largely absent. The term ‘human rights’ appears only three times without substantial explanation, and there is no reference to the Nigerian Constitution. As highlighted by Neil Richards in ‘Why Privacy Matters,’ privacy is crucial for a fair, just, and equitable digital society. The draft should integrate stronger privacy protections and align with constitutional guarantees.
Issues with Terminology and Legal References
The document contains several typographical and factual errors. For example, it refers to the “National Data Protection Act 2023” instead of the “Nigeria Data Protection Act 2023.” There are also issues with terminology and outdated references, such as the repealed Copyright Act of 2004. Terms like “data” and “sensitive data” are used inconsistently, and the document would benefit from a definitions section to clarify these terms.
Misconception of NDPA Coverage
The draft inaccurately claims that the 2023 Data Protection Act does not address AI-related data concepts. In reality, the NDPA covers various aspects of data protection relevant to AI, including automated decision-making and data lifecycle management. The document should better align with existing regulations and provide more precise guidance.
Ethical Principles and Regulation
Page 27 of the draft outlines ethical principles for AI, but privacy is omitted from the strategies proposed on page 40. The document needs to clarify whether these ethical principles will be enforceable or remain as guidelines. Additionally, there is a proposal for an AI Governance Regulatory Body on page 42, but the existing Nigeria Data Protection Commission (NDPC) is underfunded. Prioritizing funding for the NDPC or leveraging existing bodies like the National Centre for AI and Robotics (NCAIR) might be more efficient.
Conclusion
The draft National AI Strategy requires significant revisions to address privacy and data protection concerns, correct inaccuracies, and clarify its objectives. A revised document with clear, actionable goals and stronger privacy protections will better serve Nigeria’s digital economy and ensure the ethical development of AI technologies.
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