Chatbot-sovellus osana viranomaisten neuvontapalveluja
Avainsanat:
hallinto-oikeus, tekoäly, sähköinen asiointi, neuvonta, hyvä hallinto, sähköinen hallintoAbstrakti
Chatbot applications as a part of authorities’ advisory services
The purpose of this article is to analyse what kind of limits the legislation sets to authorities when they use artificial intelligent (AI) technology for the implementation of digital advisory services. Additionally, the author examines how customers’ rights have to be taken into consideration when using new AI technology in the implementation of advice.
A chatbot is an artificial-intelligence-based application that can replace a human in authorities’ routine advisory services. Under the Administrative Procedure Act (434/2003), the authorities have the duty to give advice as an administrative task. Section 124 of The Constitution of Finland limits the delegation of administrative tasks to others than the authorities. Due to this reason a chatbot application’s content management delegation is limited as regards the private sector.
The legislation requires that the answers given by chatbots must be easy to understand, clear, to the point, faultless and sufficiently comprehensive. Advice given to the customers of administration may give rise to legitimate expectations. The protection of legitimate expectations underlines the duty of authorities to ensure that chatbots’ answers are of high quality. Under Article 32 of the GDPR, the authorities have to assess how an AI application affects customers’ rights and freedoms. For that reason the authorities have to evaluate risks in the deployment phase of AI applications as chatbots – the use of an application may fall within requirements of good governance, protection under the law and data protection.
