In a new article, researchers introduce the capabilities approach-contextual integrity (CA-CI), a framework that addresses privacy and dignity risks posed by modern artificial intelligence (AI) systems, especially foundation models whose capabilities evolve across contexts and purposes. In a case study, they demonstrate how CA-CI can operationalize the European Union (EU)’s AI Act’s fundamental rights impact assessments, harm thresholds, and anticipatory governance.
The article, by researchers at Carnegie Mellon University and the University of Michigan, is published in IEEE Security & Privacy .
“By grounding AI oversight in both contextual norms and universal dignity requirements, our framework offers a practical and robust approach to operationalizing ethics in AI governance,” explains Kirsten Martin, dean of Carnegie Mellon’s Heinz College of Information Systems and Public Policy, who coauthored the study. Kat Roemmich, research associate at the University of Michigan, led the study, and Florian Schaub, associate professor of information as well as electrical engineering and computer science at the University of Michigan, is a coauthor.
The widespread use of AI systems carries with it risks to privacy and challenges to governance that correspond with models’ complexity, autonomy, and cross-domain integration. Regulators, providers, and users struggle to manage risks within systems that learn and generalize autonomously. As these systems evolve, the once-assumed observability, traceability, and contextual stability of information flows erodes as their potential for breach, misuse, and harms to dignity increases.
Addressing these challenges requires a governance framework that can evaluate the normative appropriateness of AI systems beyond narrow tasks and stable contexts, a challenge the authors addressed by integrating contextual integrity with the capabilities approach. Specifically, CA-CI:
“Uniting contextual integrity and the capabilities approach into a single normative governance framework, CA–CI evaluates privacy and dignity in any socio-technical context by whether it secures the integrity of social life and each human life within it,” says Martin, who pointed to Roemmich’s dissertation as the foundation of the framework.
The EU’s the General Data Protection Regulation enshrines a purpose limitation principle, requiring data to be “collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.” It also mandates data protection impact assessments for high-risk data processing that may affect fundamental rights and freedoms.
The EU’s AI Act, passed in 2024, extends this logic, prohibiting AI practices deemed to present an unacceptable risk to fundamental rights, health, or safety. It also requires certain users of high-risk systems to conduct fundamental rights impact assessments before use and after relevant system changes, and it requires providers to maintain continuous, purpose-specific risk assessments throughout the system’s life cycle.
But the act lacks a clear standard for determining what constitutes a violation to dignity beyond broad reference to fundamental rights, according to the authors. These ambiguities hinder evaluators in determining when a given practice crosses the moral boundary of dignity, and by extension, the derivative human rights it grounds. As a result, the enforceability of dignity as a foundational normative principle becomes increasingly tenuous.
Meeting this challenge requires a normative governance framework for privacy and data protection that can substantively assess dignity risks across evolving socio-technical contexts throughout the AI life cycle. In applying CA-CI to key requirements of the EU’s AI Act, the authors show how the framework:
While the EU’s AI Act provides a compelling case study given its rights- and risk-based framework grounded in dignity, CA-CI is can be used more broadly to evaluate privacy and dignity in any socio-technical context, regardless of jurisdiction, say the authors.
IEEE Security & Privacy
CA–CI: Integrating Contextual Integrity and the Capabilities Approach for Dignity Considerations in AI Governance
3-Feb-2026