Interoperability among large-scale IT systems and the deployment of Artificial Intelligence, what problems and consequences?

The forthcoming operationalisation of interoperability among large-scale IT systems has brought to the fore numerous fundamental rights challenges, primarily with regard to the protection of personal data. What has evaded scrutiny though is the extent to relationship between the interoperability components and the deployment of Artificial Intelligence (AI) systems in the large-scale IT systems. Are these two initiatives completely separate from one another or are there interactions that need to be elucidated and if so, which accountability challenges do they pose? This article will examine these questions, arguing that interoperability is the enabler and necessary pre-requisite for the future deployment of AI systems in the operation of large-scale IT systems. It will analyse how algorithmic profiling and facial recognition will rely on specific interoperability components, namely the European Search Portal (ESP) and the shared Biometric Matching Service (sBMS). It will further stress that the future use of AI systems will rely on the development of tailor-made statistical data compiled by the Common Repository for Reporting and Statistics (CRRS), which was also established by the Interoperability Regulations (Regulation 2019/817 and Regulation 2019/818). Having established the linkages between the two concepts, the article will further analyse how this interplay creates or deepens accountability gaps in terms of diagnosing system malfunctioning and (mis)behaviour for effective remedial action. The intervention will focus on the supervision of large-scale IT systems by national data protection authorities and the European Data Protection Supervisor (EDPS) and the Schengen Evaluation and Monitoring Mechanism (SEMM) aiming to identity systemic gaps in framing and understanding the challenges posed by the IT systems