Vulnerable Populations

Vulnerable populations in AI governance refers to groups who face disproportionate harm from biased or malfunctioning AI systems, including racial and ethnic minorities, people with disabilities, low-income communities, and the elderly. These populations often have less ability to contest decisions made about them by AI and may lack resources to seek remedies when harmed. For compliance and risk management, organizations must assess whether their AI systems could discriminate against or disadvantage these groups, since such harms create legal exposure under civil rights laws, regulatory scrutiny, and reputational damage that can outweigh business benefits.

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Corporate PolicyUS2026-09-30

DraftKings AI Model Targets Chronic Losing Gamblers With Promotional Ads

DraftKings is training machine learning models on customer betting records to identify chronic losing gamblers, then serving them promotional advertising to drive re-engagement. The Electronic Frontier Foundation published an analysis naming DraftKings and framing the practice as AI-amplified consumer harm enabled entirely by first-party data. The case illustrates that existing data-minimization and consent frameworks do not prevent companies from using lawfully collected data in ways that systematically harm vulnerable customers.

DraftKings behavioral advertising consumer harm AI targeting data ethics vulnerable populations FTC enforcement model governance