Risks to privacy Neural data is more sensitive and valuable than all other categories of personal data because of the unprecedented ability to access internal thoughts.92 The collection of neural data may, in the future, make it possible to track, analyse and predict the actions and attitudes of individuals about anything from political leaning, sexual orientation or health status.93 This makes the risk to privacy of the utmost concern. Neurotechnology products record vast quantities and varieties of neural data which may be accessed, collected, stored and used/exploited without genuine consent.94 The usage of such neural data could range from marketing companies using ‘nudging’ techniques to steer users towards certain products, employers seeking to monitor employee concentration in the workplace or more recently schools seeking to ensure children are paying attention and learning in class. The risks become more serious when considering the usage of neural data by governments – especially those with poor human rights records. It has also been suggested that the decoding of neural data will one day be able to reveal additional information such as, for example, someone’s sexual orientation, leading to possible discrimination and prejudicial treatment.95 It is also possible that other personal information, such as political affiliations or religious commitments, could be inferred from neurotechnologies in coordination with other technologies. Sexual orientation is used below as an example of the risks. The 2020 update of the Global Legislation Overview of the State‑Sponsored Homophobia Report concluded that there were 67 Member States with provisions criminalising consensual same‑sex conduct, and six UN Member States that continue to 14 impose the death penalty for consensual same‑sex conduct.96 This is in addition to the many countries where individuals continue to face persecution and violence on a daily basis because of their sexual orientation or gender identity. If mental privacy is not protected, the technology could one day lead to a widespread ability to identify, isolate and even kill people based on an assessment of their perceived sexual orientation. Further, the potential inaccuracy of such neurological tools (particularly in their early development) does not reduce the risk of persecution and violence against individuals who might be targeted by this technology – whether on the basis of sexual orientation or other characteristics. Although the collection, maintenance and usage of neural data raises ethical questions in isolation, there are concerns about how this information will be used in tandem with other forms of personal data. For example, the gathering of seemingly small and innocuous pieces of personal data (browser history, location, purchase history etc) can, accumulatively, provide a detailed profile of an individual – dubbed the ‘mosaic effect’.97 Many wearable devices, such as smart watches, now record bodily functions and are openly accepted by consumers. While this allows for the collection of information such as heart rate, geolocation and movement, with the inclusion of neural data this will also allow sensitive personal information to be extracted or inferred about a person on an unprecedented scale.98 Although only a very small percentage of brain scans can currently be decoded, the rapid advancement of AI (and other forms of technology and data) will likely see this increase. Protecting Cognition: Background Paper on Human Rights and Neurotechnology

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