AI RMF Playbook

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AI RMF

PLAYBOOK
Table of Contents
Govern ........................................................................................................................................................................... 5
GOVERN 1.1 ............................................................................................................................................................ 5
GOVERN 1.2 ............................................................................................................................................................ 6
GOVERN 1.3 ............................................................................................................................................................ 8
GOVERN 1.4 ......................................................................................................................................................... 10
GOVERN 1.5 ......................................................................................................................................................... 11
GOVERN 1.6 ......................................................................................................................................................... 13
GOVERN 1.7 ......................................................................................................................................................... 14
GOVERN 2.1 ......................................................................................................................................................... 15
GOVERN 2.2 ......................................................................................................................................................... 17
GOVERN 2.3 ......................................................................................................................................................... 18
GOVERN 3.1 ......................................................................................................................................................... 19
GOVERN 3.2 ......................................................................................................................................................... 21
GOVERN 4.1 ......................................................................................................................................................... 22
GOVERN 4.2 ......................................................................................................................................................... 24
GOVERN 4.3 ......................................................................................................................................................... 26
GOVERN 5.1 ......................................................................................................................................................... 28
GOVERN 5.2 ......................................................................................................................................................... 29
GOVERN 6.1 ......................................................................................................................................................... 31
GOVERN 6.2 ......................................................................................................................................................... 32
Manage ....................................................................................................................................................................... 34
MANAGE 1.1 ........................................................................................................................................................ 34
MANAGE 1.2 ........................................................................................................................................................ 35
MANAGE 1.3 ........................................................................................................................................................ 36
MANAGE 1.4 ........................................................................................................................................................ 38
MANAGE 2.1 ........................................................................................................................................................ 39
MANAGE 2.2 ........................................................................................................................................................ 40
MANAGE 2.3 ........................................................................................................................................................ 46
MANAGE 2.4 ........................................................................................................................................................ 48
MANAGE 3.1 ........................................................................................................................................................ 49
MANAGE 3.2 ........................................................................................................................................................ 51
MANAGE 4.1 ........................................................................................................................................................ 52
MANAGE 4.2 ........................................................................................................................................................ 53
MANAGE 4.3 ........................................................................................................................................................ 54
Map .............................................................................................................................................................................. 56
MAP 1.1 ................................................................................................................................................................. 56
MAP 1.2 ................................................................................................................................................................. 60
MAP 1.3 ................................................................................................................................................................. 61
MAP 1.4 ................................................................................................................................................................. 62
MAP 1.5 ................................................................................................................................................................. 64
MAP 1.6 ................................................................................................................................................................. 65
MAP 2.1 ................................................................................................................................................................. 68
MAP 2.2 ................................................................................................................................................................. 68
MAP 2.3 ................................................................................................................................................................. 71
MAP 3.1 ................................................................................................................................................................. 75
MAP 3.2 ................................................................................................................................................................. 76
MAP 3.3 ................................................................................................................................................................. 78
MAP 3.4 ................................................................................................................................................................. 79
MAP 3.5 ................................................................................................................................................................. 82
MAP 4.1 ................................................................................................................................................................. 84
MAP 4.2 ................................................................................................................................................................. 85
MAP 5.1 ................................................................................................................................................................. 86
MAP 5.2 ................................................................................................................................................................. 87
Measure ..................................................................................................................................................................... 90
MEASURE 1.1 ...................................................................................................................................................... 90
MEASURE 1.2 ...................................................................................................................................................... 92
MEASURE 1.3 ...................................................................................................................................................... 93
MEASURE 2.1 ...................................................................................................................................................... 95
MEASURE 2.2 ...................................................................................................................................................... 96
MEASURE 2.3 ...................................................................................................................................................... 99
MEASURE 2.4 ................................................................................................................................................... 101
MEASURE 2.5 ................................................................................................................................................... 102
MEASURE 2.6 ................................................................................................................................................... 104
MEASURE 2.7 ................................................................................................................................................... 106
MEASURE 2.8 ................................................................................................................................................... 108
MEASURE 2.9 ................................................................................................................................................... 110
MEASURE 2.10 ................................................................................................................................................ 114
MEASURE 2.11 ................................................................................................................................................ 116
MEASURE 2.12 ................................................................................................................................................ 122
MEASURE 2.13 ................................................................................................................................................ 123
MEASURE 3.1 ................................................................................................................................................... 125
MEASURE 3.2 ................................................................................................................................................... 126
MEASURE 3.3 ................................................................................................................................................... 127
MEASURE 4.1 ................................................................................................................................................... 129
MEASURE 4.2 ................................................................................................................................................... 132
MEASURE 4.3 ................................................................................................................................................... 134
About the Playbook
FORWARD
The Playbook provides suggested actions for achieving the outcomes laid out in
the AI Risk Management Framework (AI RMF) Core (Tables 1 – 4 in AI RMF
1.0). Suggestions are aligned to each sub-category within the four AI RMF
functions (Govern, Map, Measure, Manage).

The Playbook is neither a checklist nor set of steps to be followed in its entirety.

Playbook suggestions are voluntary. Organizations may utilize this information


by borrowing as many – or as few – suggestions as apply to their industry use
case or interests.

Govern Map Measure Manage


GOVERN
Govern
Policies, processes, procedures and practices across the organization related to the
mapping, measuring and managing of AI risks are in place, transparent, and implemented
effectively.

GOVERN 1.1
Legal and regulatory requirements involving AI are understood, managed, and documented.

About
AI systems may be subject to specific applicable legal and regulatory requirements. Some
legal requirements can mandate (e.g., nondiscrimination, data privacy and security
controls) documentation, disclosure, and increased AI system transparency. These
requirements are complex and may not be applicable or differ across applications and
contexts.

For example, AI system testing processes for bias measurement, such as disparate impact,
are not applied uniformly within the legal context. Disparate impact is broadly defined as a
facially neutral policy or practice that disproportionately harms a group based on a
protected trait. Notably, some modeling algorithms or debiasing techniques that rely on
demographic information, could also come into tension with legal prohibitions on disparate
treatment (i.e., intentional discrimination).

Additionally, some intended users of AI systems may not have consistent or reliable access
to fundamental internet technologies (a phenomenon widely described as the “digital
divide”) or may experience difficulties interacting with AI systems due to disabilities or
impairments. Such factors may mean different communities experience bias or other
negative impacts when trying to access AI systems. Failure to address such design issues
may pose legal risks, for example in employment related activities affecting persons with
disabilities.

Suggested Actions
• Maintain awareness of the applicable legal and regulatory considerations and
requirements specific to industry, sector, and business purpose, as well as the
application context of the deployed AI system.
• Align risk management efforts with applicable legal standards.
• Maintain policies for training (and re-training) organizational staff about necessary
legal or regulatory considerations that may impact AI-related design, development and
deployment activities.

Transparency & Documentation

Organizations can document the following


• To what extent has the entity defined and documented the regulatory environment—
including minimum requirements in laws and regulations?

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• Has the system been reviewed for its compliance to applicable laws, regulations,
standards, and guidance?
• To what extent has the entity defined and documented the regulatory environment—
including applicable requirements in laws and regulations?
• Has the system been reviewed for its compliance to relevant applicable laws,
regulations, standards, and guidance?

AI Transparency Resources
GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Andrew Smith, "Using Artificial Intelligence and Algorithms," FTC Business Blog (2020).

Rebecca Kelly Slaughter, "Algorithms and Economic Justice," ISP Digital Future Whitepaper
& YJoLT Special Publication (2021).

Patrick Hall, Benjamin Cox, Steven Dickerson, Arjun Ravi Kannan, Raghu Kulkarni, and
Nicholas Schmidt, "A United States fair lending perspective on machine learning," Frontiers
in Artificial Intelligence 4 (2021).

AI Hiring Tools and the Law, Partnership on Employment & Accessible Technology (PEAT,
peatworks.org).

GOVERN 1.2
The characteristics of trustworthy AI are integrated into organizational policies, processes,
and procedures.

About
Policies, processes, and procedures are central components of effective AI risk management
and fundamental to individual and organizational accountability. All stakeholders benefit
from policies, processes, and procedures which require preventing harm by design and
default.

Organizational policies and procedures will vary based on available resources and risk
profiles, but can help systematize AI actor roles and responsibilities throughout the AI
lifecycle. Without such policies, risk management can be subjective across the organization,
and exacerbate rather than minimize risks over time. Policies, or summaries thereof, are
understandable to relevant AI actors. Policies reflect an understanding of the underlying
metrics, measurements, and tests that are necessary to support policy and AI system design,
development, deployment and use.

Lack of clear information about responsibilities and chains of command will limit the
effectiveness of risk management.

Suggested Actions
Organizational AI risk management policies should be designed to:

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• Define key terms and concepts related to AI systems and the scope of their purposes
and intended uses.
• Connect AI governance to existing organizational governance and risk controls.
• Align to broader data governance policies and practices, particularly the use of sensitive
or otherwise risky data.
• Detail standards for experimental design, data quality, and model training.
• Outline and document risk mapping and measurement processes and standards.
• Detail model testing and validation processes.
• Detail review processes for legal and risk functions.
• Establish the frequency of and detail for monitoring, auditing and review processes.
• Outline change management requirements.
• Outline processes for internal and external stakeholder engagement.
• Establish whistleblower policies to facilitate reporting of serious AI system concerns.
• Detail and test incident response plans.
• Verify that formal AI risk management policies align to existing legal standards, and
industry best practices and norms.
• Establish AI risk management policies that broadly align to AI system trustworthy
characteristics.
• Verify that formal AI risk management policies include currently deployed and third-
party AI systems.

Transparency & Documentation

Organizations can document the following


• To what extent do these policies foster public trust and confidence in the use of the AI
system?
• What policies has the entity developed to ensure the use of the AI system is consistent
with its stated values and principles?
• What policies and documentation has the entity developed to encourage the use of its AI
system as intended?
• To what extent are the model outputs consistent with the entity’s values and principles
to foster public trust and equity?

AI Transparency Resources
GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

GAO, “Artificial Intelligence: An Accountability Framework for Federal Agencies and Other
Entities,” GAO@100 (GAO-21-519SP), June 2021.

NIST, "U.S. Leadership in AI: A Plan for Federal Engagement in Developing Technical
Standards and Related Tools".

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Lipton, Zachary and McAuley, Julian and Chouldechova, Alexandra, Does mitigating ML’s
impact disparity require treatment disparity? Advances in Neural Information Processing
Systems, 2018.

Jessica Newman (2023) “A Taxonomy of Trustworthiness for Artificial Intelligence:


Connecting Properties of Trustworthiness with Risk Management and the AI Lifecycle,” UC
Berkeley Center for Long-Term Cybersecurity.

Emily Hadley (2022). Prioritizing Policies for Furthering Responsible Artificial Intelligence
in the United States. 2022 IEEE International Conference on Big Data (Big Data), 5029-5038.

SAS Institute, “The SAS® Data Governance Framework: A Blueprint for Success”.

ISO, “Information technology — Reference Model of Data Management, “ ISO/IEC TR


10032:200.

“Play 5: Create a formal policy,” Partnership on Employment & Accessible Technology


(PEAT, peatworks.org).

"National Institute of Standards and Technology. (2018). Framework for improving critical
infrastructure cybersecurity.

Kaitlin R. Boeckl and Naomi B. Lefkovitz. "NIST Privacy Framework: A Tool for Improving
Privacy Through Enterprise Risk Management, Version 1.0." National Institute of Standards
and Technology (NIST), January 16, 2020.

“plainlanguage.gov – Home,” The U.S. Government.

GOVERN 1.3
Processes and procedures are in place to determine the needed level of risk management
activities based on the organization's risk tolerance.

About
Risk management resources are finite in any organization. Adequate AI governance policies
delineate the mapping, measurement, and prioritization of risks to allocate resources
toward the most material issues for an AI system to ensure effective risk management.
Policies may specify systematic processes for assigning mapped and measured risks to
standardized risk scales.

AI risk tolerances range from negligible to critical – from, respectively, almost no risk to
risks that can result in irredeemable human, reputational, financial, or environmental
losses. Risk tolerance rating policies consider different sources of risk, (e.g., financial,
operational, safety and wellbeing, business, reputational, or model risks). A typical risk
measurement approach entails the multiplication, or qualitative combination, of measured
or estimated impact and likelihood of impacts into a risk score (risk ≈ impact x likelihood).
This score is then placed on a risk scale. Scales for risk may be qualitative, such as red-
amber-green (RAG), or may entail simulations or econometric approaches. Impact

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assessments are a common tool for understanding the severity of mapped risks. In the most
fulsome AI risk management approaches, all models are assigned to a risk level.

Suggested Actions
• Establish policies to define mechanisms for measuring or understanding an AI system’s
potential impacts, e.g., via regular impact assessments at key stages in the AI lifecycle,
connected to system impacts and frequency of system updates.
• Establish policies to define mechanisms for measuring or understanding the likelihood
of an AI system’s impacts and their magnitude at key stages in the AI lifecycle.
• Establish policies that define assessment scales for measuring potential AI system
impact. Scales may be qualitative, such as red-amber-green (RAG), or may entail
simulations or econometric approaches.
• Establish policies for assigning an overall risk measurement approach for an AI system,
or its important components, e.g., via multiplication or combination of a mapped risk’s
impact and likelihood (risk ≈ impact x likelihood).
• Establish policies to assign systems to uniform risk scales that are valid across the
organization’s AI portfolio (e.g. documentation templates), and acknowledge risk
tolerance and risk levels may change over the lifecycle of an AI system.

Transparency & Documentation

Organizations can document the following


• How do system performance metrics inform risk tolerance decisions?
• What policies has the entity developed to ensure the use of the AI system is consistent
with organizational risk tolerance?
• How do the entity’s data security and privacy assessments inform risk tolerance
decisions?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

The Office of the Comptroller of the Currency. Enterprise Risk Appetite Statement. (Nov. 20,
2019).

Brenda Boultwood, How to Develop an Enterprise Risk-Rating Approach (Aug. 26, 2021).
Global Association of Risk Professionals (garp.org). Accessed Jan. 4, 2023.

GAO-17-63: Enterprise Risk Management: Selected Agencies’ Experiences Illustrate Good


Practices in Managing Risk.

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GOVERN 1.4
The risk management process and its outcomes are established through transparent
policies, procedures, and other controls based on organizational risk priorities.

About
Clear policies and procedures relating to documentation and transparency facilitate and
enhance efforts to communicate roles and responsibilities for the Map, Measure and
Manage functions across the AI lifecycle. Standardized documentation can help
organizations systematically integrate AI risk management processes and enhance
accountability efforts. For example, by adding their contact information to a work product
document, AI actors can improve communication, increase ownership of work products,
and potentially enhance consideration of product quality. Documentation may generate
downstream benefits related to improved system replicability and robustness. Proper
documentation storage and access procedures allow for quick retrieval of critical
information during a negative incident. Explainable machine learning efforts (models and
explanatory methods) may bolster technical documentation practices by introducing
additional information for review and interpretation by AI Actors.

Suggested Actions
• Establish and regularly review documentation policies that, among others, address
information related to:
• Verify documentation policies for AI systems are standardized across the organization
and remain current.
• Establish policies for a model documentation inventory system and regularly review its
completeness, usability, and efficacy.
• Establish mechanisms to regularly review the efficacy of risk management processes.
• Identify AI actors responsible for evaluating efficacy of risk management processes and
approaches, and for course-correction based on results.
• Establish policies and processes regarding public disclosure of the use of AI and risk
management material such as impact assessments, audits, model documentation and
validation and testing results.
• Document and review the use and efficacy of different types of transparency tools and
follow industry standards at the time a model is in use.

Transparency & Documentation

Organizations can document the following


• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?
• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• How will the appropriate performance metrics, such as accuracy, of the AI be monitored
after the AI is deployed? How much distributional shift or model drift from baseline
performance is acceptable?

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AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.

References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011).

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

Margaret Mitchell et al., “Model Cards for Model Reporting.” Proceedings of 2019 FATML
Conference.

Timnit Gebru et al., “Datasheets for Datasets,” Communications of the ACM 64, No. 12, 2021.

Emily M. Bender, Batya Friedman, Angelina McMillan-Major (2022). A Guide for Writing
Data Statements for Natural Language Processing. University of Washington. Accessed July
14, 2022.

M. Arnold, R. K. E. Bellamy, M. Hind, et al. FactSheets: Increasing trust in AI services through


supplier’s declarations of conformity. IBM Journal of Research and Development 63, 4/5
(July-September 2019), 6:1-6:13.

Navdeep Gill, Abhishek Mathur, Marcos V. Conde (2022). A Brief Overview of AI Governance
for Responsible Machine Learning Systems. ArXiv, abs/2211.13130.

John Richards, David Piorkowski, Michael Hind, et al. A Human-Centered Methodology for
Creating AI FactSheets. Bulletin of the IEEE Computer Society Technical Committee on Data
Engineering.

Christoph Molnar, Interpretable Machine Learning, lulu.com.

David A. Broniatowski. 2021. Psychological Foundations of Explainability and


Interpretability in Artificial Intelligence. National Institute of Standards and Technology
(NIST) IR 8367. National Institute of Standards and Technology, Gaithersburg, MD.

OECD (2022), “OECD Framework for the Classification of AI systems”, OECD Digital
Economy Papers, No. 323, OECD Publishing, Paris.

GOVERN 1.5
Ongoing monitoring and periodic review of the risk management process and its outcomes
are planned, organizational roles and responsibilities are clearly defined, including
determining the frequency of periodic review.

About
AI systems are dynamic and may perform in unexpected ways once deployed or after
deployment. Continuous monitoring is a risk management process for tracking unexpected

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issues and performance changes, in real-time or at a specific frequency, across the AI
system lifecycle.

Incident response and “appeal and override” are commonly used processes in information
technology management. These processes enable real-time flagging of potential incidents,
and human adjudication of system outcomes.

Establishing and maintaining incident response plans can reduce the likelihood of additive
impacts during an AI incident. Smaller organizations which may not have fulsome
governance programs, can utilize incident response plans for addressing system failures,
abuse or misuse.

Suggested Actions
• Establish policies to allocate appropriate resources and capacity for assessing impacts
of AI systems on individuals, communities and society.
• Establish policies and procedures for monitoring and addressing AI system
performance and trustworthiness, including bias and security problems, across the
lifecycle of the system.
• Establish policies for AI system incident response, or confirm that existing incident
response policies apply to AI systems.
• Establish policies to define organizational functions and personnel responsible for AI
system monitoring and incident response activities.
• Establish mechanisms to enable the sharing of feedback from impacted individuals or
communities about negative impacts from AI systems.
• Establish mechanisms to provide recourse for impacted individuals or communities to
contest problematic AI system outcomes.
• Establish opt-out mechanisms.

Transparency & Documentation

Organizations can document the following


• To what extent does the system/entity consistently measure progress towards stated
goals and objectives?
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• Did your organization address usability problems and test whether user interfaces
served their intended purposes?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Model AI Governance Framework Assessment 2020.

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References
National Institute of Standards and Technology. (2018). Framework for improving critical
infrastructure cybersecurity.

National Institute of Standards and Technology. (2012). Computer Security Incident


Handling Guide. NIST Special Publication 800-61 Revision 2.

GOVERN 1.6
Mechanisms are in place to inventory AI systems and are resourced according to
organizational risk priorities.

About
An AI system inventory is an organized database of artifacts relating to an AI system or
model. It may include system documentation, incident response plans, data dictionaries,
links to implementation software or source code, names and contact information for
relevant AI actors, or other information that may be helpful for model or system
maintenance and incident response purposes. AI system inventories also enable a holistic
view of organizational AI assets. A serviceable AI system inventory may allow for the quick
resolution of:

• specific queries for single models, such as “when was this model last refreshed?”
• high-level queries across all models, such as, “how many models are currently deployed
within our organization?” or “how many users are impacted by our models?”

AI system inventories are a common element of traditional model risk management


approaches and can provide technical, business and risk management benefits. Typically
inventories capture all organizational models or systems, as partial inventories may not
provide the value of a full inventory.

Suggested Actions
• Establish policies that define the creation and maintenance of AI system inventories.
• Establish policies that define a specific individual or team that is responsible for
maintaining the inventory.
• Establish policies that define which models or systems are inventoried, with preference
to inventorying all models or systems, or minimally, to high risk models or systems, or
systems deployed in high-stakes settings.
• Establish policies that define model or system attributes to be inventoried, e.g,
documentation, links to source code, incident response plans, data dictionaries, AI actor
contact information.

Transparency & Documentation

Organizations can document the following


• Who is responsible for documenting and maintaining the AI system inventory details?

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• What processes exist for data generation, acquisition/collection, ingestion,
staging/storage, transformations, security, maintenance, and dissemination?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.

References
“A risk-based integrity level schema”, in IEEE 1012, IEEE Standard for System, Software,
and Hardware Verification and Validation. See Annex B.

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).
See “Model Inventory,” pg. 26.

VertaAI, “ModelDB: An open-source system for Machine Learning model versioning,


metadata, and experiment management.” Accessed Jan. 5, 2023.

GOVERN 1.7
Processes and procedures are in place for decommissioning and phasing out of AI systems
safely and in a manner that does not increase risks or decrease the organization’s
trustworthiness.

About
Irregular or indiscriminate termination or deletion of models or AI systems may be
inappropriate and increase organizational risk. For example, AI systems may be subject to
regulatory requirements or implicated in future security or legal investigations. To maintain
trust, organizations may consider establishing policies and processes for the systematic and
deliberate decommissioning of AI systems. Typically, such policies consider user and
community concerns, risks in dependent and linked systems, and security, legal or
regulatory concerns. Decommissioned models or systems may be stored in a model
inventory along with active models, for an established length of time.

Suggested Actions
• Establish policies for decommissioning AI systems. Such policies typically address:
• Establish policies that delineate where and for how long decommissioned systems,
models and related artifacts are stored.
• Establish practices to track accountability and consider how decommission and other
adaptations or changes in system deployment contribute to downstream impacts for
individuals, groups and communities.
• Establish policies that address ancillary data or artifacts that must be preserved for
fulsome understanding or execution of the decommissioned AI system, e.g., predictions,
explanations, intermediate input feature representations, usernames and passwords,
etc.

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Transparency & Documentation

Organizations can document the following


• What processes exist for data generation, acquisition/collection, ingestion,
staging/storage, transformations, security, maintenance, and dissemination?
• To what extent do these policies foster public trust and confidence in the use of the AI
system?
• If anyone believes that the AI no longer meets this ethical framework, who will be
responsible for receiving the concern and as appropriate investigating and remediating
the issue? Do they have authority to modify, limit, or stop the use of the AI?
• If it relates to people, were there any ethical review applications/reviews/approvals?
(e.g. Institutional Review Board applications)

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• Datasheets for Datasets.

References
Michelle De Mooy, Joseph Jerome and Vijay Kasschau, “Should It Stay or Should It Go? The
Legal, Policy and Technical Landscape Around Data Deletion,” Center for Democracy and
Technology, 2017.

Burcu Baykurt, "Algorithmic accountability in US cities: Transparency, impact, and political


economy." Big Data & Society 9, no. 2 (2022): 20539517221115426.

Upol Ehsan, Ranjit Singh, Jacob Metcalf and Mark O. Riedl. “The Algorithmic Imprint.”
Proceedings of the 2022 ACM Conference on Fairness, Accountability, and Transparency
(2022).

“Information System Decommissioning Guide,” Bureau of Land Management, 2011.

GOVERN 2.1
Roles and responsibilities and lines of communication related to mapping, measuring, and
managing AI risks are documented and are clear to individuals and teams throughout the
organization.

About
The development of a risk-aware organizational culture starts with defining
responsibilities. For example, under some risk management structures, professionals
carrying out test and evaluation tasks are independent from AI system developers and
report through risk management functions or directly to executives. This kind of structure
may help counter implicit biases such as groupthink or sunk cost fallacy and bolster risk
management functions, so efforts are not easily bypassed or ignored.

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Instilling a culture where AI system design and implementation decisions can be questioned
and course- corrected by empowered AI actors can enhance organizations’ abilities to
anticipate and effectively manage risks before they become ingrained.

Suggested Actions
• Establish policies that define the AI risk management roles and responsibilities for
positions directly and indirectly related to AI systems, including, but not limited to
• Establish policies that promote regular communication among AI actors participating in
AI risk management efforts.
• Establish policies that separate management of AI system development functions from
AI system testing functions, to enable independent course-correction of AI systems.
• Establish policies to identify, increase the transparency of, and prevent conflicts of
interest in AI risk management efforts.
• Establish policies to counteract confirmation bias and market incentives that may
hinder AI risk management efforts.
• Establish policies that incentivize AI actors to collaborate with existing legal, oversight,
compliance, or enterprise risk functions in their AI risk management activities.

Transparency & Documentation

Organizations can document the following


• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?
• Who is ultimately responsible for the decisions of the AI and is this person aware of the
intended uses and limitations of the analytic?
• Are the responsibilities of the personnel involved in the various AI governance
processes clearly defined?
• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• Did your organization implement accountability-based practices in data management
and protection (e.g. the PDPA and OECD Privacy Principles)?

AI Transparency Resources
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Andrew Smith, “Using Artificial Intelligence and Algorithms,” FTC Business Blog (Apr. 8,
2020).

Off. Superintendent Fin. Inst. Canada, Enterprise-Wide Model Risk Management for Deposit-
Taking Institutions, E-23 (Sept. 2017).

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Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011).

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

ISO, “Information Technology — Artificial Intelligence — Guidelines for AI applications,”


ISO/IEC CD 5339. See Section 6, “Stakeholders’ perspectives and AI application framework.”

GOVERN 2.2
The organization’s personnel and partners receive AI risk management training to enable
them to perform their duties and responsibilities consistent with related policies,
procedures, and agreements.

About
To enhance AI risk management adoption and effectiveness, organizations are encouraged
to identify and integrate appropriate training curricula into enterprise learning
requirements. Through regular training, AI actors can maintain awareness of:

• AI risk management goals and their role in achieving them.


• Organizational policies, applicable laws and regulations, and industry best practices and
norms.

See [MAP 3.4]() and [3.5]() for additional relevant information.

Suggested Actions
• Establish policies for personnel addressing ongoing education about:
• Ensure that trainings are suitable across AI actor sub-groups - for AI actors carrying out
technical tasks (e.g., developers, operators, etc.) as compared to AI actors in oversight
roles (e.g., legal, compliance, audit, etc.).
• Ensure that trainings comprehensively address technical and socio-technical aspects of
AI risk management.
• Verify that organizational AI policies include mechanisms for internal AI personnel to
acknowledge and commit to their roles and responsibilities.
• Verify that organizational policies address change management and include
mechanisms to communicate and acknowledge substantial AI system changes.
• Define paths along internal and external chains of accountability to escalate risk
concerns.

Transparency & Documentation

Organizations can document the following


• Are the relevant staff dealing with AI systems properly trained to interpret AI model
output and decisions as well as to detect and manage bias in data?
• How does the entity determine the necessary skills and experience needed to design,
develop, deploy, assess, and monitor the AI system?

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• How does the entity assess whether personnel have the necessary skills, training,
resources, and domain knowledge to fulfill their assigned responsibilities?
• What efforts has the entity undertaken to recruit, develop, and retain a workforce with
backgrounds, experience, and perspectives that reflect the community impacted by the
AI system?

AI Transparency Resources
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

“Developing Staff Trainings for Equitable AI,” Partnership on Employment & Accessible
Technology (PEAT, peatworks.org).

GOVERN 2.3
Executive leadership of the organization takes responsibility for decisions about risks
associated with AI system development and deployment.

About
Senior leadership and members of the C-Suite in organizations that maintain an AI portfolio,
should maintain awareness of AI risks, affirm the organizational appetite for such risks, and
be responsible for managing those risks..

Accountability ensures that a specific team and individual is responsible for AI risk
management efforts. Some organizations grant authority and resources (human and
budgetary) to a designated officer who ensures adequate performance of the institution’s AI
portfolio (e.g. predictive modeling, machine learning).

Suggested Actions
• Organizational management can:
• Organizations can establish board committees for AI risk management and oversight
functions and integrate those functions within the organization’s broader enterprise
risk management approaches.

Transparency & Documentation

Organizations can document the following


• Did your organization’s board and/or senior management sponsor, support and
participate in your organization’s AI governance?
• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?

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• Do AI solutions provide sufficient information to assist the personnel to make an
informed decision and take actions accordingly?
• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?

AI Transparency Resources
• WEF Companion to the Model AI Governance Framework- 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011)

Off. Superintendent Fin. Inst. Canada, Enterprise-Wide Model Risk Management for Deposit-
Taking Institutions, E-23 (Sept. 2017).

GOVERN 3.1
Decision-makings related to mapping, measuring, and managing AI risks throughout the
lifecycle is informed by a diverse team (e.g., diversity of demographics, disciplines,
experience, expertise, and backgrounds).

About
A diverse team that includes AI actors with diversity of experience, disciplines, and
backgrounds to enhance organizational capacity and capability for anticipating risks is
better equipped to carry out risk management. Consultation with external personnel may
be necessary when internal teams lack a diverse range of lived experiences or disciplinary
expertise.

To extend the benefits of diversity, equity, and inclusion to both the users and AI actors, it is
recommended that teams are composed of a diverse group of individuals who reflect a
range of backgrounds, perspectives and expertise.

Without commitment from senior leadership, beneficial aspects of team diversity and
inclusion can be overridden by unstated organizational incentives that inadvertently
conflict with the broader values of a diverse workforce.

Suggested Actions
Organizational management can:

• Define policies and hiring practices at the outset that promote interdisciplinary roles,
competencies, skills, and capacity for AI efforts.
• Define policies and hiring practices that lead to demographic and domain expertise
diversity; empower staff with necessary resources and support, and facilitate the
contribution of staff feedback and concerns without fear of reprisal.
• Establish policies that facilitate inclusivity and the integration of new insights into
existing practice.

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• Seek external expertise to supplement organizational diversity, equity, inclusion, and
accessibility where internal expertise is lacking.
• Establish policies that incentivize AI actors to collaborate with existing
nondiscrimination, accessibility and accommodation, and human resource functions,
employee resource group (ERGs), and diversity, equity, inclusion, and accessibility
(DEIA) initiatives.

Transparency & Documentation

Organizations can document the following


• Are the relevant staff dealing with AI systems properly trained to interpret AI model
output and decisions as well as to detect and manage bias in data?
• Entities include diverse perspectives from technical and non-technical communities
throughout the AI life cycle to anticipate and mitigate unintended consequences
including potential bias and discrimination.
• Stakeholder involvement: Include diverse perspectives from a community of
stakeholders throughout the AI life cycle to mitigate risks.
• Strategies to incorporate diverse perspectives include establishing collaborative
processes and multidisciplinary teams that involve subject matter experts in data
science, software development, civil liberties, privacy and security, legal counsel, and
risk management.
• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?

AI Transparency Resources
• WEF Model AI Governance Framework Assessment 2020.
• Datasheets for Datasets.

References
Dylan Walsh, “How can human-centered AI fight bias in machines and people?” MIT Sloan
Mgmt. Rev., 2021.

Michael Li, “To Build Less-Biased AI, Hire a More Diverse Team,” Harvard Bus. Rev., 2020.

Bo Cowgill et al., “Biased Programmers? Or Biased Data? A Field Experiment in


Operationalizing AI Ethics,” 2020.

Naomi Ellemers, Floortje Rink, “Diversity in work groups,” Current opinion in psychology,
vol. 11, pp. 49–53, 2016.

Katrin Talke, Søren Salomo, Alexander Kock, “Top management team diversity and strategic
innovation orientation: The relationship and consequences for innovativeness and
performance,” Journal of Product Innovation Management, vol. 28, pp. 819–832, 2011.

Sarah Myers West, Meredith Whittaker, and Kate Crawford,, “Discriminating Systems:
Gender, Race, and Power in AI,” AI Now Institute, Tech. Rep., 2019.

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Sina Fazelpour, Maria De-Arteaga, Diversity in sociotechnical machine learning systems. Big
Data & Society. January 2022. doi:10.1177/20539517221082027

Mary L. Cummings and Songpo Li, 2021a. Sources of subjectivity in machine learning
models. ACM Journal of Data and Information Quality, 13(2), 1–9

“Staffing for Equitable AI: Roles & Responsibilities,” Partnership on Employment &
Accessible Technology (PEAT, peatworks.org). Accessed Jan. 6, 2023.

GOVERN 3.2
Policies and procedures are in place to define and differentiate roles and responsibilities for
human-AI configurations and oversight of AI systems.

About
Identifying and managing AI risks and impacts are enhanced when a broad set of
perspectives and actors across the AI lifecycle, including technical, legal, compliance, social
science, and human factors expertise is engaged. AI actors include those who operate, use,
or interact with AI systems for downstream tasks, or monitor AI system performance.
Effective risk management efforts include:

• clear definitions and differentiation of the various human roles and responsibilities for
AI system oversight and governance
• recognizing and clarifying differences between AI system overseers and those using or
interacting with AI systems.

Suggested Actions
• Establish policies and procedures that define and differentiate the various human roles
and responsibilities when using, interacting with, or monitoring AI systems.
• Establish procedures for capturing and tracking risk information related to human-AI
configurations and associated outcomes.
• Establish policies for the development of proficiency standards for AI actors carrying
out system operation tasks and system oversight tasks.
• Establish specified risk management training protocols for AI actors carrying out
system operation tasks and system oversight tasks.
• Establish policies and procedures regarding AI actor roles, and responsibilities for
human oversight of deployed systems.
• Establish policies and procedures defining human-AI configurations (configurations
where AI systems are explicitly designated and treated as team members in primarily
human teams) in relation to organizational risk tolerances, and associated
documentation.
• Establish policies to enhance the explanation, interpretation, and overall transparency
of AI systems.
• Establish policies for managing risks regarding known difficulties in human-AI
configurations, human-AI teaming, and AI system user experience and user interactions
(UI/UX).

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Transparency & Documentation

Organizations can document the following


• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?
• To what extent has the entity documented the appropriate level of human involvement
in AI-augmented decision-making?
• How will the accountable human(s) address changes in accuracy and precision due to
either an adversary’s attempts to disrupt the AI or unrelated changes in
operational/business environment, which may impact the accuracy of the AI?
• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?
• How does the entity assess whether personnel have the necessary skills, training,
resources, and domain knowledge to fulfill their assigned responsibilities?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• WEF Companion to the Model AI Governance Framework- 2020.

References
Madeleine Clare Elish, "Moral Crumple Zones: Cautionary tales in human-robot interaction,"
Engaging Science, Technology, and Society, Vol. 5, 2019.

“Human-AI Teaming: State-Of-The-Art and Research Needs,” National Academies of


Sciences, Engineering, and Medicine, 2022.

Ben Green, "The Flaws Of Policies Requiring Human Oversight Of Government Algorithms,"
Computer Law & Security Review 45 (2022).

David A. Broniatowski. 2021. Psychological Foundations of Explainability and


Interpretability in Artificial Intelligence. National Institute of Standards and Technology
(NIST) IR 8367. National Institute of Standards and Technology, Gaithersburg, MD.

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

GOVERN 4.1
Organizational policies, and practices are in place to foster a critical thinking and safety-first
mindset in the design, development, deployment, and uses of AI systems to minimize
negative impacts.

About
A risk culture and accompanying practices can help organizations effectively triage the most
critical risks. Organizations in some industries implement three (or more) “lines of

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defense,” where separate teams are held accountable for different aspects of the system
lifecycle, such as development, risk management, and auditing. While a traditional three-
lines approach may be impractical for smaller organizations, leadership can commit to
cultivating a strong risk culture through other means. For example, “effective challenge,” is a
culture- based practice that encourages critical thinking and questioning of important
design and implementation decisions by experts with the authority and stature to make
such changes.

Red-teaming is another risk measurement and management approach. This practice


consists of adversarial testing of AI systems under stress conditions to seek out failure
modes or vulnerabilities in the system. Red-teams are composed of external experts or
personnel who are independent from internal AI actors.

Suggested Actions
• Establish policies that require inclusion of oversight functions (legal, compliance, risk
management) from the outset of the system design process.
• Establish policies that promote effective challenge of AI system design, implementation,
and deployment decisions, via mechanisms such as the three lines of defense, model
audits, or red-teaming – to minimize workplace risks such as groupthink.
• Establish policies that incentivize safety-first mindset and general critical thinking and
review at an organizational and procedural level.
• Establish whistleblower protections for insiders who report on perceived serious
problems with AI systems.
• Establish policies to integrate a harm and risk prevention mindset throughout the AI
lifecycle.

Transparency & Documentation

Organizations can document the following


• To what extent has the entity documented the AI system’s development, testing
methodology, metrics, and performance outcomes?
• Are organizational information sharing practices widely followed and transparent, such
that related past failed designs can be avoided?
• Are training manuals and other resources for carrying out incident response
documented and available?
• Are processes for operator reporting of incidents and near-misses documented and
available?

AI Transparency Resources
• Datasheets for Datasets.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Model AI Governance Framework Assessment 2020.

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References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011)

Patrick Hall, Navdeep Gill, and Benjamin Cox, “Responsible Machine Learning,” O’Reilly
Media, 2020.

Off. Superintendent Fin. Inst. Canada, Enterprise-Wide Model Risk Management for Deposit-
Taking Institutions, E-23 (Sept. 2017).

GAO, “Artificial Intelligence: An Accountability Framework for Federal Agencies and Other
Entities,” GAO@100 (GAO-21-519SP), June 2021.

Donald Sull, Stefano Turconi, and Charles Sull, “When It Comes to Culture, Does Your
Company Walk the Talk?” MIT Sloan Mgmt. Rev., 2020.

Kathy Baxter, AI Ethics Maturity Model, Salesforce.

GOVERN 4.2
Organizational teams document the risks and potential impacts of the AI technology they
design, develop, deploy, evaluate and use, and communicate about the impacts more
broadly.

About
Impact assessments are one approach for driving responsible technology development
practices. And, within a specific use case, these assessments can provide a high-level
structure for organizations to frame risks of a given algorithm or deployment. Impact
assessments can also serve as a mechanism for organizations to articulate risks and
generate documentation for managing and oversight activities when harms do arise.

Impact assessments may:

• be applied at the beginning of a process but also iteratively and regularly since goals
and outcomes can evolve over time.
• include perspectives from AI actors, including operators, users, and potentially
impacted communities (including historically marginalized communities, those with
disabilities, and individuals impacted by the digital divide),
• assist in “go/no-go” decisions for an AI system.
• consider conflicts of interest, or undue influence, related to the organizational team
being assessed.

See the MAP function playbook guidance for more information relating to impact
assessments.

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Suggested Actions
• Establish impact assessment policies and processes for AI systems used by the
organization.
• Align organizational impact assessment activities with relevant regulatory or legal
requirements.
• Verify that impact assessment activities are appropriate to evaluate the potential
negative impact of a system and how quickly a system changes, and that assessments
are applied on a regular basis.
• Utilize impact assessments to inform broader evaluations of AI system risk.

Transparency & Documentation

Organizations can document the following


• How has the entity identified and mitigated potential impacts of bias in the data,
including inequitable or discriminatory outcomes?
• How has the entity documented the AI system’s data provenance, including sources,
origins, transformations, augmentations, labels, dependencies, constraints, and
metadata?
• To what extent has the entity clearly defined technical specifications and requirements
for the AI system?
• To what extent has the entity documented and communicated the AI system’s
development, testing methodology, metrics, and performance outcomes?
• Have you documented and explained that machine errors may differ from human
errors?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Datasheets for Datasets.

References
Dillon Reisman, Jason Schultz, Kate Crawford, Meredith Whittaker, “Algorithmic Impact
Assessments: A Practical Framework For Public Agency Accountability,” AI Now Institute,
2018.

H.R. 2231, 116th Cong. (2019).

BSA The Software Alliance (2021) Confronting Bias: BSA’s Framework to Build Trust in AI.

Anthony M. Barrett, Dan Hendrycks, Jessica Newman and Brandie Nonnecke. Actionable
Guidance for High-Consequence AI Risk Management: Towards Standards Addressing AI
Catastrophic Risks. ArXiv abs/2206.08966 (2022) https://arxiv.org/abs/2206.08966

David Wright, “Making Privacy Impact Assessments More Effective." The Information
Society 29, 2013.

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Konstantinia Charitoudi and Andrew Blyth. A Socio-Technical Approach to Cyber Risk
Management and Impact Assessment. Journal of Information Security 4, 1 (2013), 33-41.

Emanuel Moss, Elizabeth Anne Watkins, Ranjit Singh, Madeleine Clare Elish, & Jacob Metcalf.
2021. “Assembling Accountability: Algorithmic Impact Assessment for the Public Interest”.

Microsoft. Responsible AI Impact Assessment Template. 2022.

Microsoft. Responsible AI Impact Assessment Guide. 2022.

Microsoft. Foundations of assessing harm. 2022.

Mauritz Kop, “AI Impact Assessment & Code of Conduct,” Futurium, May 2019.

Dillon Reisman, Jason Schultz, Kate Crawford, and Meredith Whittaker, “Algorithmic Impact
Assessments: A Practical Framework For Public Agency Accountability,” AI Now, Apr. 2018.

Andrew D. Selbst, “An Institutional View Of Algorithmic Impact Assessments,” Harvard


Journal of Law & Technology, vol. 35, no. 1, 2021

Ada Lovelace Institute. 2022. Algorithmic Impact Assessment: A Case Study in Healthcare.
Accessed July 14, 2022.

Kathy Baxter, AI Ethics Maturity Model, Salesforce

GOVERN 4.3
Organizational practices are in place to enable AI testing, identification of incidents, and
information sharing.

About
Identifying AI system limitations, detecting and tracking negative impacts and incidents,
and sharing information about these issues with appropriate AI actors will improve risk
management. Issues such as concept drift, AI bias and discrimination, shortcut learning or
underspecification are difficult to identify using current standard AI testing processes.
Organizations can institute in-house use and testing policies and procedures to identify and
manage such issues. Efforts can take the form of pre-alpha or pre-beta testing, or deploying
internally developed systems or products within the organization. Testing may entail
limited and controlled in-house, or publicly available, AI system testbeds, and accessibility
of AI system interfaces and outputs.

Without policies and procedures that enable consistent testing practices, risk management
efforts may be bypassed or ignored, exacerbating risks or leading to inconsistent risk
management activities.

Information sharing about impacts or incidents detected during testing or deployment can:

• draw attention to AI system risks, failures, abuses or misuses,

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• allow organizations to benefit from insights based on a wide range of AI applications
and implementations, and
• allow organizations to be more proactive in avoiding known failure modes.

Organizations may consider sharing incident information with the AI Incident Database, the
AIAAIC, users, impacted communities, or with traditional cyber vulnerability databases,
such as the MITRE CVE list.

Suggested Actions
• Establish policies and procedures to facilitate and equip AI system testing.
• Establish organizational commitment to identifying AI system limitations and sharing of
insights about limitations within appropriate AI actor groups.
• Establish policies for reporting and documenting incident response.
• Establish policies and processes regarding public disclosure of incidents and
information sharing.
• Establish guidelines for incident handling related to AI system risks and performance.

Transparency & Documentation

Organizations can document the following


• Did your organization address usability problems and test whether user interfaces
served their intended purposes? Consulting the community or end users at the earliest
stages of development to ensure there is transparency on the technology used and how
it is deployed.
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?

AI Transparency Resources
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.

References
Sean McGregor, “Preventing Repeated Real World AI Failures by Cataloging Incidents: The
AI Incident Database,” arXiv:2011.08512 [cs], Nov. 2020, arXiv:2011.08512.

Christopher Johnson, Mark Badger, David Waltermire, Julie Snyder, and Clem Skorupka,
“Guide to cyber threat information sharing,” National Institute of Standards and Technology,
NIST Special Publication 800-150, Nov 2016.

Mengyi Wei, Zhixuan Zhou (2022). AI Ethics Issues in Real World: Evidence from AI Incident
Database. ArXiv, abs/2206.07635.

BSA The Software Alliance (2021) Confronting Bias: BSA’s Framework to Build Trust in AI.

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“Using Combined Expertise to Evaluate Web Accessibility,” W3C Web Accessibility Initiative.

GOVERN 5.1
Organizational policies and practices are in place to collect, consider, prioritize, and
integrate feedback from those external to the team that developed or deployed the AI
system regarding the potential individual and societal impacts related to AI risks.

About
Beyond internal and laboratory-based system testing, organizational policies and practices
may consider AI system fitness-for-purpose related to the intended context of use.

Participatory stakeholder engagement is one type of qualitative activity to help AI actors


answer questions such as whether to pursue a project or how to design with impact in
mind. This type of feedback, with domain expert input, can also assist AI actors to identify
emergent scenarios and risks in certain AI applications. The consideration of when and how
to convene a group and the kinds of individuals, groups, or community organizations to
include is an iterative process connected to the system's purpose and its level of risk. Other
factors relate to how to collaboratively and respectfully capture stakeholder feedback and
insight that is useful, without being a solely perfunctory exercise.

These activities are best carried out by personnel with expertise in participatory practices,
qualitative methods, and translation of contextual feedback for technical audiences.

Participatory engagement is not a one-time exercise and is best carried out from the very
beginning of AI system commissioning through the end of the lifecycle. Organizations can
consider how to incorporate engagement when beginning a project and as part of their
monitoring of systems. Engagement is often utilized as a consultative practice, but this
perspective may inadvertently lead to “participation washing.” Organizational transparency
about the purpose and goal of the engagement can help mitigate that possibility.

Organizations may also consider targeted consultation with subject matter experts as a
complement to participatory findings. Experts may assist internal staff in identifying and
conceptualizing potential negative impacts that were previously not considered.

Suggested Actions
• Establish AI risk management policies that explicitly address mechanisms for collecting,
evaluating, and incorporating stakeholder and user feedback that could include:
• Verify that stakeholder feedback is considered and addressed, including environmental
concerns, and across the entire population of intended users, including historically
excluded populations, people with disabilities, older people, and those with limited
access to the internet and other basic technologies.
• Clarify the organization’s principles as they apply to AI systems – considering those
which have been proposed publicly – to inform external stakeholders of the
organization’s values. Consider publishing or adopting AI principles.

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Transparency & Documentation

Organizations can document the following


• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?
• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?
• How easily accessible and current is the information available to external stakeholders?
• What was done to mitigate or reduce the potential for harm?
• Stakeholder involvement: Include diverse perspectives from a community of
stakeholders throughout the AI life cycle to mitigate risks.

AI Transparency Resources
• Datasheets for Datasets.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.
• Stakeholders in Explainable AI, Sep. 2018.

References
ISO, “Ergonomics of human-system interaction — Part 210: Human-centered design for
interactive systems,” ISO 9241-210:2019 (2nd ed.), July 2019.

Rumman Chowdhury and Jutta Williams, "Introducing Twitter’s first algorithmic bias
bounty challenge,"

Leonard Haas and Sebastian Gießler, “In the realm of paper tigers – exploring the failings of
AI ethics guidelines,” AlgorithmWatch, 2020.

Josh Kenway, Camille Francois, Dr. Sasha Costanza-Chock, Inioluwa Deborah Raji, & Dr. Joy
Buolamwini. 2022. Bug Bounties for Algorithmic Harms? Algorithmic Justice League.
Accessed July 14, 2022.

Microsoft Community Jury , Azure Application Architecture Guide.

“Definition of independent verification and validation (IV&V)”, in IEEE 1012, IEEE Standard
for System, Software, and Hardware Verification and Validation. Annex C,

GOVERN 5.2
Mechanisms are established to enable AI actors to regularly incorporate adjudicated
feedback from relevant AI actors into system design and implementation.

About
Organizational policies and procedures that equip AI actors with the processes, knowledge,
and expertise needed to inform collaborative decisions about system deployment improve

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risk management. These decisions are closely tied to AI systems and organizational risk
tolerance.

Risk tolerance, established by organizational leadership, reflects the level and type of risk
the organization will accept while conducting its mission and carrying out its strategy.
When risks arise, resources are allocated based on the assessed risk of a given AI system.
Organizations typically apply a risk tolerance approach where higher risk systems receive
larger allocations of risk management resources and lower risk systems receive less
resources.

Suggested Actions
• Explicitly acknowledge that AI systems, and the use of AI, present inherent costs and
risks along with potential benefits.
• Define reasonable risk tolerances for AI systems informed by laws, regulation, best
practices, or industry standards.
• Establish policies that ensure all relevant AI actors are provided with meaningful
opportunities to provide feedback on system design and implementation.
• Establish policies that define how to assign AI systems to established risk tolerance
levels by combining system impact assessments with the likelihood that an impact
occurs. Such assessment often entails some combination of:
• Establish policies facilitating the early decommissioning of AI systems that surpass an
organization’s ability to reasonably mitigate risks.

Transparency & Documentation

Organizations can document the following


• Who is ultimately responsible for the decisions of the AI and is this person aware of the
intended uses and limitations of the analytic?
• Who will be responsible for maintaining, re-verifying, monitoring, and updating this AI
once deployed?
• Who is accountable for the ethical considerations during all stages of the AI lifecycle?
• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?
• Does the AI solution provide sufficient information to assist the personnel to make an
informed decision and take actions accordingly?

AI Transparency Resources
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• Stakeholders in Explainable AI, Sep. 2018.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.

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References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011)

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

The Office of the Comptroller of the Currency. Enterprise Risk Appetite Statement. (Nov. 20,
2019). Retrieved on July 12, 2022.

GOVERN 6.1
Policies and procedures are in place that address AI risks associated with third-party
entities, including risks of infringement of a third party’s intellectual property or other
rights.

About
Risk measurement and management can be complicated by how customers use or integrate
third-party data or systems into AI products or services, particularly without sufficient
internal governance structures and technical safeguards.

Organizations usually engage multiple third parties for external expertise, data, software
packages (both open source and commercial), and software and hardware platforms across
the AI lifecycle. This engagement has beneficial uses and can increase complexities of risk
management efforts.

Organizational approaches to managing third-party (positive and negative) risk may be


tailored to the resources, risk profile, and use case for each system. Organizations can apply
governance approaches to third-party AI systems and data as they would for internal
resources — including open source software, publicly available data, and commercially
available models.

Suggested Actions
• Collaboratively establish policies that address third-party AI systems and data.
• Establish policies related to:
• Evaluate policies for third-party technology.
• Establish policies that address supply chain, full product lifecycle and associated
processes, including legal, ethical, and other issues concerning procurement and use of
third-party software or hardware systems and data.

Transparency & Documentation

Organizations can document the following


• Did you establish mechanisms that facilitate the AI system’s auditability (e.g.
traceability of the development process, the sourcing of training data and the logging of
the AI system’s processes, outcomes, positive and negative impact)?
• If a third party created the AI, how will you ensure a level of explainability or
interpretability?

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• Did you ensure that the AI system can be audited by independent third parties?
• Did you establish a process for third parties (e.g. suppliers, end users, subjects,
distributors/vendors or workers) to report potential vulnerabilities, risks or biases in
the AI system?
• To what extent does the plan specifically address risks associated with acquisition,
procurement of packaged software from vendors, cybersecurity controls, computational
infrastructure, data, data science, deployment mechanics, and system failure?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI -
2019.

References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011)

“Proposed Interagency Guidance on Third-Party Relationships: Risk Management,” 2021.

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

GOVERN 6.2
Contingency processes are in place to handle failures or incidents in third-party data or AI
systems deemed to be high-risk.

About
To mitigate the potential harms of third-party system failures, organizations may
implement policies and procedures that include redundancies for covering third-party
functions.

Suggested Actions
• Establish policies for handling third-party system failures to include consideration of
redundancy mechanisms for vital third-party AI systems.
• Verify that incident response plans address third-party AI systems.

Transparency & Documentation

Organizations can document the following


• To what extent does the plan specifically address risks associated with acquisition,
procurement of packaged software from vendors, cybersecurity controls, computational
infrastructure, data, data science, deployment mechanics, and system failure?

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• Did you establish a process for third parties (e.g. suppliers, end users, subjects,
distributors/vendors or workers) to report potential vulnerabilities, risks or biases in
the AI system?
• If your organization obtained datasets from a third party, did your organization assess
and manage the risks of using such datasets?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.

References
Bd. Governors Fed. Rsrv. Sys., Supervisory Guidance on Model Risk Management, SR Letter
11-7 (Apr. 4, 2011)

“Proposed Interagency Guidance on Third-Party Relationships: Risk Management,” 2021.

Off. Comptroller Currency, Comptroller’s Handbook: Model Risk Management (Aug. 2021).

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MANAGE
Manage
AI risks based on assessments and other analytical output from the Map and Measure
functions are prioritized, responded to, and managed.

MANAGE 1.1
A determination is made as to whether the AI system achieves its intended purpose and
stated objectives and whether its development or deployment should proceed.

About
AI systems may not necessarily be the right solution for a given business task or problem. A
standard risk management practice is to formally weigh an AI system’s negative risks
against its benefits, and to determine if the AI system is an appropriate solution. Tradeoffs
among trustworthiness characteristics —such as deciding to deploy a system based on
system performance vs system transparency–may require regular assessment throughout
the AI lifecycle.

Suggested Actions
• Consider trustworthiness characteristics when evaluating AI systems’ negative risks
and benefits.
• Utilize TEVV outputs from map and measure functions when considering risk treatment.
• Regularly track and monitor negative risks and benefits throughout the AI system
lifecycle including in post-deployment monitoring.
• Regularly assess and document system performance relative to trustworthiness
characteristics and tradeoffs between negative risks and opportunities.
• Evaluate tradeoffs in connection with real-world use cases and impacts and as
enumerated in Map function outcomes.

Transparency & Documentation

Organizations can document the following


• How do the technical specifications and requirements align with the AI system’s goals
and objectives?
• To what extent are the metrics consistent with system goals, objectives, and constraints,
including ethical and compliance considerations?
• What goals and objectives does the entity expect to achieve by designing, developing,
and/or deploying the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations

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References
Arvind Narayanan. How to recognize AI snake oil. Retrieved October 15, 2022.

Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, Jacob Metcalf. 2021.
Assembling Accountability: Algorithmic Impact Assessment for the Public Interest. (June 29,
2021).

Fraser, Henry L and Bello y Villarino, Jose-Miguel, Where Residual Risks Reside: A
Comparative Approach to Art 9(4) of the European Union's Proposed AI Regulation
(September 30, 2021). [LINK](https://ssrn.com/abstract=3960461),

Microsoft. 2022. Microsoft Responsible AI Impact Assessment Template. (June 2022).

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Solon Barocas, Asia J. Biega, Benjamin Fish, et al. 2020. When not to design, build, or deploy.
In Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency (FAT*
'20). Association for Computing Machinery, New York, NY, USA, 695.

MANAGE 1.2
Treatment of documented AI risks is prioritized based on impact, likelihood, or available
resources or methods.

About
Risk refers to the composite measure of an event’s probability of occurring and the
magnitude (or degree) of the consequences of the corresponding events. The impacts, or
consequences, of AI systems can be positive, negative, or both and can result in
opportunities or risks.

Organizational risk tolerances are often informed by several internal and external factors,
including existing industry practices, organizational values, and legal or regulatory
requirements. Since risk management resources are often limited, organizations usually
assign them based on risk tolerance. AI risks that are deemed more serious receive more
oversight attention and risk management resources.

Suggested Actions
• Assign risk management resources relative to established risk tolerance. AI systems
with lower risk tolerances receive greater oversight, mitigation and management
resources.
• Document AI risk tolerance determination practices and resource decisions.
• Regularly review risk tolerances and re-calibrate, as needed, in accordance with
information from AI system monitoring and assessment .

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Transparency & Documentation

Organizations can document the following


• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• What assessments has the entity conducted on data security and privacy impacts
associated with the AI system?
• Does your organization have an existing governance structure that can be leveraged to
oversee the organization’s use of AI?

AI Transparency Resources
• WEF Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

References
Arvind Narayanan. How to recognize AI snake oil. Retrieved October 15, 2022.

Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, Jacob Metcalf. 2021.
Assembling Accountability: Algorithmic Impact Assessment for the Public Interest. (June 29,
2021).

Fraser, Henry L and Bello y Villarino, Jose-Miguel, Where Residual Risks Reside: A
Comparative Approach to Art 9(4) of the European Union's Proposed AI Regulation
(September 30, 2021). [LINK](https://ssrn.com/abstract=3960461),

Microsoft. 2022. Microsoft Responsible AI Impact Assessment Template. (June 2022).

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Solon Barocas, Asia J. Biega, Benjamin Fish, et al. 2020. When not to design, build, or deploy.
In Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency (FAT*
'20). Association for Computing Machinery, New York, NY, USA, 695.

MANAGE 1.3
Responses to the AI risks deemed high priority as identified by the Map function, are
developed, planned, and documented. Risk response options can include mitigating,
transferring, avoiding, or accepting.

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About
Outcomes from GOVERN-1, MAP-5 and MEASURE-2, can be used to address and document
identified risks based on established risk tolerances. Organizations can follow existing
regulations and guidelines for risk criteria, tolerances and responses established by
organizational, domain, discipline, sector, or professional requirements. In lieu of such
guidance, organizations can develop risk response plans based on strategies such as
accepted model risk management, enterprise risk management, and information sharing
and disclosure practices.

Suggested Actions
• Observe regulatory and established organizational, sector, discipline, or professional
standards and requirements for applying risk tolerances within the organization.
• Document procedures for acting on AI system risks related to trustworthiness
characteristics.
• Prioritize risks involving physical safety, legal liabilities, regulatory compliance, and
negative impacts on individuals, groups, or society.
• Identify risk response plans and resources and organizational teams for carrying out
response functions.
• Store risk management and system documentation in an organized, secure repository
that is accessible by relevant AI Actors and appropriate personnel.

Transparency & Documentation

Organizations can document the following


• Has the system been reviewed to ensure the AI system complies with relevant laws,
regulations, standards, and guidance?
• To what extent has the entity defined and documented the regulatory environment—
including minimum requirements in laws and regulations?
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Datasheets for Datasets.

References
Arvind Narayanan. How to recognize AI snake oil. Retrieved October 15, 2022.

Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

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Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, Jacob Metcalf. 2021.
Assembling Accountability: Algorithmic Impact Assessment for the Public Interest. (June 29,
2021).

Fraser, Henry L and Bello y Villarino, Jose-Miguel, Where Residual Risks Reside: A
Comparative Approach to Art 9(4) of the European Union's Proposed AI Regulation
(September 30, 2021). [LINK](https://ssrn.com/abstract=3960461),

Microsoft. 2022. Microsoft Responsible AI Impact Assessment Template. (June 2022).

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Solon Barocas, Asia J. Biega, Benjamin Fish, et al. 2020. When not to design, build, or deploy.
In Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency (FAT*
'20). Association for Computing Machinery, New York, NY, USA, 695.

MANAGE 1.4
Negative residual risks (defined as the sum of all unmitigated risks) to both downstream
acquirers of AI systems and end users are documented.

About
Organizations may choose to accept or transfer some of the documented risks from MAP
and MANAGE 1.3 and 2.1. Such risks, known as residual risk, may affect downstream AI
actors such as those engaged in system procurement or use. Transparent monitoring and
managing residual risks enables cost benefit analysis and the examination of potential
values of AI systems versus its potential negative impacts.

Suggested Actions
• Document residual risks within risk response plans, denoting risks that have been
accepted, transferred, or subject to minimal mitigation.
• Establish procedures for disclosing residual risks to relevant downstream AI actors .
• Inform relevant downstream AI actors of requirements for safe operation, known
limitations, and suggested warning labels as identified in MAP 3.4.

Transparency & Documentation

Organizations can document the following


• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• Who will be responsible for maintaining, re-verifying, monitoring, and updating this AI
once deployed?
• How will updates/revisions be documented and communicated? How often and by
whom?
• How easily accessible and current is the information available to external stakeholders?

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AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• Datasheets for Datasets.

References
Arvind Narayanan. How to recognize AI snake oil. Retrieved October 15, 2022.

Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, Jacob Metcalf. 2021.
Assembling Accountability: Algorithmic Impact Assessment for the Public Interest. (June 29,
2021).

Fraser, Henry L and Bello y Villarino, Jose-Miguel, Where Residual Risks Reside: A
Comparative Approach to Art 9(4) of the European Union's Proposed AI Regulation
(September 30, 2021). [LINK](https://ssrn.com/abstract=3960461),

Microsoft. 2022. Microsoft Responsible AI Impact Assessment Template. (June 2022).

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Solon Barocas, Asia J. Biega, Benjamin Fish, et al. 2020. When not to design, build, or deploy.
In Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency (FAT*
'20). Association for Computing Machinery, New York, NY, USA, 695.

MANAGE 2.1
Resources required to manage AI risks are taken into account, along with viable non-AI
alternative systems, approaches, or methods – to reduce the magnitude or likelihood of
potential impacts.

About
Organizational risk response may entail identifying and analyzing alternative approaches,
methods, processes or systems, and balancing tradeoffs between trustworthiness
characteristics and how they relate to organizational principles and societal values. Analysis
of these tradeoffs is informed by consulting with interdisciplinary organizational teams,
independent domain experts, and engaging with individuals or community groups. These
processes require sufficient resource allocation.

Suggested Actions
• Plan and implement risk management practices in accordance with established
organizational risk tolerances.
• Verify risk management teams are resourced to carry out functions, including

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• Identify resource allocation approaches for managing risks in systems:
• Regularly seek and integrate external expertise and perspectives to supplement
organizational diversity (e.g. demographic, disciplinary), equity, inclusion, and
accessibility where internal capacity is lacking.
• Enable and encourage regular, open communication and feedback among AI actors and
internal or external stakeholders related to system design or deployment decisions.
• Prepare and document plans for continuous monitoring and feedback mechanisms.

Transparency & Documentation

Organizations can document the following


• Are mechanisms in place to evaluate whether internal teams are empowered and
resourced to effectively carry out risk management functions?
• How will user and other forms of stakeholder engagement be integrated into risk
management processes?

AI Transparency Resources
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• Datasheets for Datasets.
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

References
Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

David Wright. 2013. Making Privacy Impact Assessments More Effective. The Information
Society, 29 (Oct 2013), 307-315.

Margaret Mitchell, Simone Wu, Andrew Zaldivar, et al. 2019. Model Cards for Model
Reporting. In Proceedings of the Conference on Fairness, Accountability, and Transparency
(FAT* '19). Association for Computing Machinery, New York, NY, USA, 220–229.

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Timnit Gebru, Jamie Morgenstern, Briana Vecchione, et al. 2021. Datasheets for Datasets.
arXiv:1803.09010.

MANAGE 2.2
Mechanisms are in place and applied to sustain the value of deployed AI systems.

About
System performance and trustworthiness may evolve and shift over time, once an AI system
is deployed and put into operation. This phenomenon, generally known as drift, can degrade
the value of the AI system to the organization and increase the likelihood of negative

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impacts. Regular monitoring of AI systems’ performance and trustworthiness enhances
organizations’ ability to detect and respond to drift, and thus sustain an AI system’s value
once deployed. Processes and mechanisms for regular monitoring address system
functionality and behavior - as well as impacts and alignment with the values and norms
within the specific context of use. For example, considerations regarding impacts on
personal or public safety or privacy may include limiting high speeds when operating
autonomous vehicles or restricting illicit content recommendations for minors.

Regular monitoring activities can enable organizations to systematically and proactively


identify emergent risks and respond according to established protocols and metrics.
Options for organizational responses include 1) avoiding the risk, 2)accepting the risk, 3)
mitigating the risk, or 4) transferring the risk. Each of these actions require planning and
resources. Organizations are encouraged to establish risk management protocols with
consideration of the trustworthiness characteristics, the deployment context, and real
world impacts.

Suggested Actions
• Establish risk controls considering trustworthiness characteristics, including:

• Data management, quality, and privacy (e.g. minimization, rectification or


deletion requests) controls as part of organizational data governance policies.
• Machine learning and end-point security countermeasures (e.g., robust models,
differential privacy, authentication, throttling).
• Business rules that augment, limit or restrict AI system outputs within certain
contexts
• Utilizing domain expertise related to deployment context for continuous
improvement and TEVV across the AI lifecycle.
• Development and regular tracking of human-AI teaming configurations.
• Model assessment and test, evaluation, validation and verification (TEVV)
protocols.
• Use of standardized documentation and transparency mechanisms.
• Software quality assurance practices across AI lifecycle.
• Mechanisms to explore system limitations and avoid past failed designs or
deployments.

• Establish mechanisms to capture feedback from system end users and potentially
impacted groups while system is in deployment.
• stablish mechanisms to capture feedback from system end users and potentially
impacted groups about how changes in system deployment (e.g., introducing new
technology, decommissioning algorithms and models, adapting system, model or
algorithm) may create negative impacts that are not visible along the AI lifecycle.
• Review insurance policies, warranties, or contracts for legal or oversight requirements
for risk transfer procedures.
• Document risk tolerance decisions and risk acceptance procedures.

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Transparency & Documentation

Organizations can document the following


• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• Could the AI system expose people to harm or negative impacts? What was done to
mitigate or reduce the potential for harm?
• How will the accountable human(s) address changes in accuracy and precision due to
either an adversary’s attempts to disrupt the AI or unrelated changes in the operational
or business environment?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References

Safety, Validity and Reliability Risk Management Approaches and Resources


AI Incident Database. 2022. AI Incident Database.

AIAAIC Repository. 2022. AI, algorithmic and automation incidents collected, dissected,
examined, and divulged.

Alexander D'Amour, Katherine Heller, Dan Moldovan, et al. 2020. Underspecification


Presents Challenges for Credibility in Modern Machine Learning. arXiv:2011.03395.

Andrew L. Beam, Arjun K. Manrai, Marzyeh Ghassemi. 2020. Challenges to the


Reproducibility of Machine Learning Models in Health Care. Jama 323, 4 (January 6, 2020),
305-306.

Anthony M. Barrett, Dan Hendrycks, Jessica Newman et al. 2022. Actionable Guidance for
High-Consequence AI Risk Management: Towards Standards Addressing AI Catastrophic
Risks. arXiv:2206.08966.

Debugging Machine Learning Models, In Proceedings of ICLR 2019 Workshop, May 6, 2019,
New Orleans, Louisiana.

Jessie J. Smith, Saleema Amershi, Solon Barocas, et al. 2022. REAL ML: Recognizing,
Exploring, and Articulating Limitations of Machine Learning Research. arXiv:2205.08363.

Joelle Pineau, Philippe Vincent-Lamarre, Koustuv Sinha, et al. 2020. Improving


Reproducibility in Machine Learning Research (A Report from the NeurIPS 2019
Reproducibility Program) arXiv:2003.12206.

Kirstie Whitaker. 2017. Showing your working: a how to guide to reproducible research.
(August 2017).

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[LINK](https://github.com/WhitakerLab/ReproducibleResearch/blob/master/PRESENTA
TIONS/Whitaker_ICON_August2017.pdf),

Netflix. Chaos Monkey.

Peter Henderson, Riashat Islam, Philip Bachman, et al. 2018. Deep reinforcement learning
that matters. Proceedings of the AAAI Conference on Artificial Intelligence. 32, 1 (Apr.
2018).

Suchi Saria, Adarsh Subbaswamy. 2019. Tutorial: Safe and Reliable Machine Learning.
arXiv:1904.07204.

Kang, Daniel, Deepti Raghavan, Peter Bailis, and Matei Zaharia. "Model assertions for
monitoring and improving ML models." Proceedings of Machine Learning and Systems 2
(2020): 481-496.

Managing Risk Bias


National Institute of Standards and Technology (NIST), Reva Schwartz, Apostol Vassilev, et
al. 2022. NIST Special Publication 1270 Towards a Standard for Identifying and Managing
Bias in Artificial Intelligence.

Bias Testing and Remediation Approaches


Alekh Agarwal, Alina Beygelzimer, Miroslav Dudík, et al. 2018. A Reductions Approach to
Fair Classification. arXiv:1803.02453.

Brian Hu Zhang, Blake Lemoine, Margaret Mitchell. 2018. Mitigating Unwanted Biases with
Adversarial Learning. arXiv:1801.07593.

Drago Plečko, Nicolas Bennett, Nicolai Meinshausen. 2021. Fairadapt: Causal Reasoning for
Fair Data Pre-processing. arXiv:2110.10200.

Faisal Kamiran, Toon Calders. 2012. Data Preprocessing Techniques for Classification
without Discrimination. Knowledge and Information Systems 33 (2012), 1–33.

Faisal Kamiran; Asim Karim; Xiangliang Zhang. 2012. Decision Theory for Discrimination-
Aware Classification. In Proceedings of the 2012 IEEE 12th International Conference on
Data Mining, December 10-13, 2012, Brussels, Belgium. IEEE, 924-929.

Flavio P. Calmon, Dennis Wei, Karthikeyan Natesan Ramamurthy, et al. 2017. Optimized
Data Pre-Processing for Discrimination Prevention. arXiv:1704.03354.

Geoff Pleiss, Manish Raghavan, Felix Wu, et al. 2017. On Fairness and Calibration.
arXiv:1709.02012.

L. Elisa Celis, Lingxiao Huang, Vijay Keswani, et al. 2020. Classification with Fairness
Constraints: A Meta-Algorithm with Provable Guarantees. arXiv:1806.06055.

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Michael Feldman, Sorelle Friedler, John Moeller, et al. 2014. Certifying and Removing
Disparate Impact. arXiv:1412.3756.

Michael Kearns, Seth Neel, Aaron Roth, et al. 2017. Preventing Fairness Gerrymandering:
Auditing and Learning for Subgroup Fairness. arXiv:1711.05144.

Michael Kearns, Seth Neel, Aaron Roth, et al. 2018. An Empirical Study of Rich Subgroup
Fairness for Machine Learning. arXiv:1808.08166.

Moritz Hardt, Eric Price, and Nathan Srebro. 2016. Equality of Opportunity in Supervised
Learning. In Proceedings of the 30th Conference on Neural Information Processing Systems
(NIPS 2016), 2016, Barcelona, Spain.

Rich Zemel, Yu Wu, Kevin Swersky, et al. 2013. Learning Fair Representations. In
Proceedings of the 30th International Conference on Machine Learning 2013, PMLR 28, 3,
325-333.

Toshihiro Kamishima, Shotaro Akaho, Hideki Asoh & Jun Sakuma. 2012. Fairness-Aware
Classifier with Prejudice Remover Regularizer. In Peter A. Flach, Tijl De Bie, Nello Cristianini
(eds) Machine Learning and Knowledge Discovery in Databases. European Conference
ECML PKDD 2012, Proceedings Part II, September 24-28, 2012, Bristol, UK. Lecture Notes in
Computer Science 7524. Springer, Berlin, Heidelberg.

Security and Resilience Resources


FTC Start With Security Guidelines. 2015.

Gary McGraw et al. 2022. BIML Interactive Machine Learning Risk Framework. Berryville
Institute for Machine Learning.

Ilia Shumailov, Yiren Zhao, Daniel Bates, et al. 2021. Sponge Examples: Energy-Latency
Attacks on Neural Networks. arXiv:2006.03463.

Marco Barreno, Blaine Nelson, Anthony D. Joseph, et al. 2010. The Security of Machine
Learning. Machine Learning 81 (2010), 121-148.

Matt Fredrikson, Somesh Jha, Thomas Ristenpart. 2015. Model Inversion Attacks that
Exploit Confidence Information and Basic Countermeasures. In Proceedings of the 22nd
ACM SIGSAC Conference on Computer and Communications Security (CCS '15), October
2015. Association for Computing Machinery, New York, NY, USA, 1322–1333.

National Institute for Standards and Technology (NIST). 2022. Cybersecurity Framework.

Nicolas Papernot. 2018. A Marauder's Map of Security and Privacy in Machine Learning.
arXiv:1811.01134.

Reza Shokri, Marco Stronati, Congzheng Song, et al. 2017. Membership Inference Attacks
against Machine Learning Models. arXiv:1610.05820.

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Adversarial Threat Matrix (MITRE). 2021.

Interpretability and Explainability Approaches


Chaofan Chen, Oscar Li, Chaofan Tao, et al. 2019. This Looks Like That: Deep Learning for
Interpretable Image Recognition. arXiv:1806.10574.

Cynthia Rudin. 2019. Stop explaining black box machine learning models for high stakes
decisions and use interpretable models instead. arXiv:1811.10154.

Daniel W. Apley, Jingyu Zhu. 2019. Visualizing the Effects of Predictor Variables in Black Box
Supervised Learning Models. arXiv:1612.08468.

David A. Broniatowski. 2021. Psychological Foundations of Explainability and


Interpretability in Artificial Intelligence. National Institute of Standards and Technology
(NIST) IR 8367. National Institute of Standards and Technology, Gaithersburg, MD.

Forough Poursabzi-Sangdeh, Daniel G. Goldstein, Jake M. Hofman, et al. 2021. Manipulating


and Measuring Model Interpretability. arXiv:1802.07810.

Hongyu Yang, Cynthia Rudin, Margo Seltzer. 2017. Scalable Bayesian Rule Lists.
arXiv:1602.08610.

P. Jonathon Phillips, Carina A. Hahn, Peter C. Fontana, et al. 2021. Four Principles of
Explainable Artificial Intelligence. National Institute of Standards and Technology (NIST) IR
8312. National Institute of Standards and Technology, Gaithersburg, MD.

Scott Lundberg, Su-In Lee. 2017. A Unified Approach to Interpreting Model Predictions.
arXiv:1705.07874.

Susanne Gaube, Harini Suresh, Martina Raue, et al. 2021. Do as AI say: susceptibility in
deployment of clinical decision-aids. npj Digital Medicine 4, Article 31 (2021).

Yin Lou, Rich Caruana, Johannes Gehrke, et al. 2013. Accurate intelligible models with
pairwise interactions. In Proceedings of the 19th ACM SIGKDD international conference on
Knowledge discovery and data mining (KDD '13), August 2013. Association for Computing
Machinery, New York, NY, USA, 623–631.

Post-Decommission
Upol Ehsan, Ranjit Singh, Jacob Metcalf and Mark O. Riedl. “The Algorithmic Imprint.”
Proceedings of the 2022 ACM Conference on Fairness, Accountability, and Transparency
(2022).

Privacy Resources
National Institute for Standards and Technology (NIST). 2022. Privacy Framework.

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Data Governance
Marijn Janssen, Paul Brous, Elsa Estevez, Luis S. Barbosa, Tomasz Janowski, Data
governance: Organizing data for trustworthy Artificial Intelligence, Government
Information Quarterly, Volume 37, Issue 3, 2020, 101493, ISSN 0740-624X.

Software Resources
• PiML (explainable models, performance assessment)
• Interpret (explainable models)
• Iml (explainable models)
• Drifter library (performance assessment)
• Manifold library (performance assessment)
• SALib library (performance assessment)
• What-If Tool (performance assessment)
• MLextend (performance assessment)

- AI Fairness 360:

• Python (bias testing and mitigation)


• R (bias testing and mitigation)
• Adversarial-robustness-toolbox (ML security)
• Robustness (ML security)
• tensorflow/privacy (ML security)
• NIST De-identification Tools (Privacy and ML security)
• Dvc (MLops, deployment)
• Gigantum (MLops, deployment)
• Mlflow (MLops, deployment)
• Mlmd (MLops, deployment)
• Modeldb (MLops, deployment)

MANAGE 2.3
Procedures are followed to respond to and recover from a previously unknown risk when it
is identified.

About
AI systems – like any technology – can demonstrate non-functionality or failure or
unexpected and unusual behavior. They also can be subject to attacks, incidents, or other
misuse or abuse – which their sources are not always known apriori. Organizations can
establish, document, communicate and maintain treatment procedures to recognize and
counter, mitigate and manage risks that were not previously identified.

Suggested Actions
• Protocols, resources, and metrics are in place for continual monitoring of AI systems’
performance, trustworthiness, and alignment with contextual norms and values

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• Establish and regularly review treatment and response plans for incidents, negative
impacts, or outcomes.
• Establish and maintain procedures to regularly monitor system components for drift,
decontextualization, or other AI system behavior factors,
• Establish and maintain procedures for capturing feedback about negative impacts.
• Verify contingency processes to handle any negative impacts associated with mission-
critical AI systems, and to deactivate systems.
• Enable preventive and post-hoc exploration of AI system limitations by relevant AI actor
groups.
• Decommission systems that exceed risk tolerances.

Transparency & Documentation

Organizations can document the following


• Who will be responsible for maintaining, re-verifying, monitoring, and updating this AI
once deployed?
• Are the responsibilities of the personnel involved in the various AI governance
processes clearly defined? (Including responsibilities to decommission the AI system.)
• What processes exist for data generation, acquisition/collection, ingestion,
staging/storage, transformations, security, maintenance, and dissemination?
• How will the appropriate performance metrics, such as accuracy, of the AI be monitored
after the AI is deployed?

AI Transparency Resources
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF - Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations.
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

References
AI Incident Database. 2022. AI Incident Database.

AIAAIC Repository. 2022. AI, algorithmic and automation incidents collected, dissected,
examined, and divulged.

Andrew Burt and Patrick Hall. 2018. What to Do When AI Fails. O’Reilly Media, Inc. (May 18,
2020). Retrieved October 17, 2022.

National Institute for Standards and Technology (NIST). 2022. Cybersecurity Framework.

SANS Institute. 2022. Security Consensus Operational Readiness Evaluation (SCORE)


Security Checklist [or Advanced Persistent Threat (APT) Handling Checklist].

Suchi Saria, Adarsh Subbaswamy. 2019. Tutorial: Safe and Reliable Machine Learning.
arXiv:1904.07204.

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MANAGE 2.4
Mechanisms are in place and applied, responsibilities are assigned and understood to
supersede, disengage, or deactivate AI systems that demonstrate performance or outcomes
inconsistent with intended use.

About
Performance inconsistent with intended use does not always increase risk or lead to
negative impacts. Rigorous TEVV practices are useful for protecting against negative
impacts regardless of intended use. When negative impacts do arise, superseding
(bypassing), disengaging, or deactivating/decommissioning a model, AI system
component(s), or the entire AI system may be necessary, such as when:

• a system reaches the end of its lifetime


• detected or identified risks exceed tolerance thresholds
• adequate system mitigation actions are beyond the organization’s capacity
• feasible system mitigation actions do not meet regulatory, legal, norms or standards.
• impending risk is detected during continual monitoring, for which feasible mitigation
cannot be identified or implemented in a timely fashion.

Safely removing AI systems from operation, either temporarily or permanently, under these
scenarios requires standard protocols that minimize operational disruption and
downstream negative impacts. Protocols can involve redundant or backup systems that are
developed in alignment with established system governance policies (see GOVERN 1.7),
regulatory compliance, legal frameworks, business requirements and norms and l standards
within the application context of use. Decision thresholds and metrics for actions to bypass
or deactivate system components are part of continual monitoring procedures. Incidents
that result in a bypass/deactivate decision require documentation and review to
understand root causes, impacts, and potential opportunities for mitigation and
redeployment. Organizations are encouraged to develop risk and change management
protocols that consider and anticipate upstream and downstream consequences of both
temporary and/or permanent decommissioning, and provide contingency options.

Suggested Actions
• Regularly review established procedures for AI system bypass actions, including plans
for redundant or backup systems to ensure continuity of operational and/or business
functionality.
• Regularly review Identify system incident thresholds for activating bypass or
deactivation responses.
• Apply change management processes to understand the upstream and downstream
consequences of bypassing or deactivating an AI system or AI system components.
• Apply protocols, resources and metrics for decisions to supersede, bypass or deactivate
AI systems or AI system components.
• Preserve materials for forensic, regulatory, and legal review.

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• Conduct internal root cause analysis and process reviews of bypass or deactivation
events.
• Decommission and preserve system components that cannot be updated to meet
criteria for redeployment.
• Establish criteria for redeploying updated system components, in consideration of
trustworthy characteristics

Transparency & Documentation

Organizations can document the following


• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• What testing, if any, has the entity conducted on the AI system to identify errors and
limitations (i.e. adversarial or stress testing)?
• To what extent does the entity have established procedures for retiring the AI system, if
it is no longer needed?
• How did the entity use assessments and/or evaluations to determine if the system can
be scaled up, continue, or be decommissioned?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

References
Decommissioning Template. Application Lifecycle And Supporting Docs. Cloud and
Infrastructure Community of Practice.

Develop a Decommission Plan. M3 Playbook. Office of Shared Services and Solutions and
Performance Improvement. General Services Administration.

MANAGE 3.1
AI risks and benefits from third-party resources are regularly monitored, and risk controls
are applied and documented.

About
AI systems may depend on external resources and associated processes, including third-
party data, software or hardware systems. Third parties’ supplying organizations with
components and services, including tools, software, and expertise for AI system design,
development, deployment or use can improve efficiency and scalability. It can also increase
complexity and opacity, and, in-turn, risk. Documenting third-party technologies, personnel,
and resources that were employed can help manage risks. Focusing first and foremost on

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risks involving physical safety, legal liabilities, regulatory compliance, and negative impacts
on individuals, groups, or society is recommended.

Suggested Actions
• Have legal requirements been addressed?
• Apply organizational risk tolerance to third-party AI systems.
• Apply and document organizational risk management plans and practices to third-party
AI technology, personnel, or other resources.
• Identify and maintain documentation for third-party AI systems and components.
• Establish testing, evaluation, validation and verification processes for third-party AI
systems which address the needs for transparency without exposing proprietary
algorithms .
• Establish processes to identify beneficial use and risk indicators in third-party systems
or components, such as inconsistent software release schedule, sparse documentation,
and incomplete software change management (e.g., lack of forward or backward
compatibility).
• Organizations can establish processes for third parties to report known and potential
vulnerabilities, risks or biases in supplied resources.
• Verify contingency processes for handling negative impacts associated with mission-
critical third-party AI systems.
• Monitor third-party AI systems for potential negative impacts and risks associated with
trustworthiness characteristics.
• Decommission third-party systems that exceed risk tolerances.

Transparency & Documentation

Organizations can document the following


• If a third party created the AI system or some of its components, how will you ensure a
level of explainability or interpretability? Is there documentation?
• If your organization obtained datasets from a third party, did your organization assess
and manage the risks of using such datasets?
• Did you establish a process for third parties (e.g. suppliers, end users, subjects,
distributors/vendors or workers) to report potential vulnerabilities, risks or biases in
the AI system?
• Have legal requirements been addressed?

AI Transparency Resources
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF - Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations.
• Datasheets for Datasets.

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References
Office of the Comptroller of the Currency. 2021. Proposed Interagency Guidance on Third-
Party Relationships: Risk Management. July 12, 2021.

MANAGE 3.2
Pre-trained models which are used for development are monitored as part of AI system
regular monitoring and maintenance.

About
A common approach in AI development is transfer learning, whereby an existing pre-
trained model is adapted for use in a different, but related application. AI actors in
development tasks often use pre-trained models from third-party entities for tasks such as
image classification, language prediction, and entity recognition, because the resources to
build such models may not be readily available to most organizations. Pre-trained models
are typically trained to address various classification or prediction problems, using
exceedingly large datasets and computationally intensive resources. The use of pre-trained
models can make it difficult to anticipate negative system outcomes or impacts. Lack of
documentation or transparency tools increases the difficulty and general complexity when
deploying pre-trained models and hinders root cause analyses.

Suggested Actions
• Identify pre-trained models within AI system inventory for risk tracking.
• Establish processes to independently and continually monitor performance and
trustworthiness of pre-trained models, and as part of third-party risk tracking.
• Monitor performance and trustworthiness of AI system components connected to pre-
trained models, and as part of third-party risk tracking.
• Identify, document and remediate risks arising from AI system components and pre-
trained models per organizational risk management procedures, and as part of third-
party risk tracking.
• Decommission AI system components and pre-trained models which exceed risk
tolerances, and as part of third-party risk tracking.

Transparency & Documentation

Organizations can document the following


• How has the entity documented the AI system’s data provenance, including sources,
origins, transformations, augmentations, labels, dependencies, constraints, and
metadata?
• Does this dataset collection/processing procedure achieve the motivation for creating
the dataset stated in the first section of this datasheet?
• How does the entity ensure that the data collected are adequate, relevant, and not
excessive in relation to the intended purpose?
• If the dataset becomes obsolete how will this be communicated?

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AI Transparency Resources
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF - Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations.
• Datasheets for Datasets.

References
Larysa Visengeriyeva et al. “Awesome MLOps,“ GitHub. Accessed January 9, 2023.

MANAGE 4.1
Post-deployment AI system monitoring plans are implemented, including mechanisms for
capturing and evaluating input from users and other relevant AI actors, appeal and
override, decommissioning, incident response, recovery, and change management.

About
AI system performance and trustworthiness can change due to a variety of factors. Regular
AI system monitoring can help deployers identify performance degradations, adversarial
attacks, unexpected and unusual behavior, near-misses, and impacts. Including pre- and
post-deployment external feedback about AI system performance can enhance
organizational awareness about positive and negative impacts, and reduce the time to
respond to risks and harms.

Suggested Actions
• Establish and maintain procedures to monitor AI system performance for risks and
negative and positive impacts associated with trustworthiness characteristics.
• Perform post-deployment TEVV tasks to evaluate AI system validity and reliability, bias
and fairness, privacy, and security and resilience.
• Evaluate AI system trustworthiness in conditions similar to deployment context of use,
and prior to deployment.
• Establish and implement red-teaming exercises at a prescribed cadence, and evaluate
their efficacy.
• Establish procedures for tracking dataset modifications such as data deletion or
rectification requests.
• Establish mechanisms for regular communication and feedback between relevant AI
actors and internal or external stakeholders to capture information about system
performance, trustworthiness and impact.
• Share information about errors, near-misses, and attack patterns with incident
databases, other organizations with similar systems, and system users and
stakeholders.
• Respond to and document detected or reported negative impacts or issues in AI system
performance and trustworthiness.
• Decommission systems that exceed establish risk tolerances.

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Transparency & Documentation

Organizations can document the following


• To what extent has the entity documented the post-deployment AI system’s testing
methodology, metrics, and performance outcomes?
• How easily accessible and current is the information available to external stakeholders?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities,
• Datasheets for Datasets.

References
Navdeep Gill, Patrick Hall, Kim Montgomery, and Nicholas Schmidt. "A Responsible Machine
Learning Workflow with Focus on Interpretable Models, Post-hoc Explanation, and
Discrimination Testing." Information 11, no. 3 (2020): 137.

MANAGE 4.2
Measurable activities for continual improvements are integrated into AI system updates
and include regular engagement with interested parties, including relevant AI actors.

About
Regular monitoring processes enable system updates to enhance performance and
functionality in accordance with regulatory and legal frameworks, and organizational and
contextual values and norms. These processes also facilitate analyses of root causes, system
degradation, drift, near-misses, and failures, and incident response and documentation.

AI actors across the lifecycle have many opportunities to capture and incorporate external
feedback about system performance, limitations, and impacts, and implement continuous
improvements. Improvements may not always be to model pipeline or system processes,
and may instead be based on metrics beyond accuracy or other quality performance
measures. In these cases, improvements may entail adaptations to business or
organizational procedures or practices. Organizations are encouraged to develop
improvements that will maintain traceability and transparency for developers, end users,
auditors, and relevant AI actors.

Suggested Actions
• Integrate trustworthiness characteristics into protocols and metrics used for continual
improvement.
• Establish processes for evaluating and integrating feedback into AI system
improvements.
• Assess and evaluate alignment of proposed improvements with relevant regulatory and
legal frameworks
• Assess and evaluate alignment of proposed improvements connected to the values and
norms within the context of use.

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• Document the basis for decisions made relative to tradeoffs between trustworthy
characteristics, system risks, and system opportunities

Transparency & Documentation

Organizations can document the following


• How will user and other forms of stakeholder engagement be integrated into the model
development process and regular performance review once deployed?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• To what extent has the entity defined and documented the regulatory environment—
including minimum requirements in laws and regulations?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities,
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Yen, Po-Yin, et al. "Development and Evaluation of Socio-Technical Metrics to Inform HIT
Adaptation."

Carayon, Pascale, and Megan E. Salwei. "Moving toward a sociotechnical systems approach
to continuous health information technology design: the path forward for improving
electronic health record usability and reducing clinician burnout." Journal of the American
Medical Informatics Association 28.5 (2021): 1026-1028.

Mishra, Deepa, et al. "Organizational capabilities that enable big data and predictive
analytics diffusion and organizational performance: A resource-based perspective."
Management Decision (2018).

MANAGE 4.3
Incidents and errors are communicated to relevant AI actors including affected
communities. Processes for tracking, responding to, and recovering from incidents and
errors are followed and documented.

About
Regularly documenting an accurate and transparent account of identified and reported
errors can enhance AI risk management activities., Examples include:

• how errors were identified,


• incidents related to the error,
• whether the error has been repaired, and
• how repairs can be distributed to all impacted stakeholders and users.

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Suggested Actions
• Establish procedures to regularly share information about errors, incidents and
negative impacts with relevant stakeholders, operators, practitioners and users, and
impacted parties.
• Maintain a database of reported errors, near-misses, incidents and negative impacts
including date reported, number of reports, assessment of impact and severity, and
responses.
• Maintain a database of system changes, reason for change, and details of how the change
was made, tested and deployed.
• Maintain version history information and metadata to enable continuous improvement
processes.
• Verify that relevant AI actors responsible for identifying complex or emergent risks are
properly resourced and empowered.

Transparency & Documentation

Organizations can document the following


• What corrective actions has the entity taken to enhance the quality, accuracy, reliability,
and representativeness of the data?
• To what extent does the entity communicate its AI strategic goals and objectives to the
community of stakeholders? How easily accessible and current is the information
available to external stakeholders?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?

AI Transparency Resources
• GAO-21-519SP: Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities,

References
Wei, M., & Zhou, Z. (2022). AI Ethics Issues in Real World: Evidence from AI Incident
Database. ArXiv, abs/2206.07635.

McGregor, Sean. "Preventing repeated real world AI failures by cataloging incidents: The AI
incident database." Proceedings of the AAAI Conference on Artificial Intelligence. Vol. 35.
No. 17. 2021.

Macrae, Carl. "Learning from the failure of autonomous and intelligent systems: Accidents,
safety, and sociotechnical sources of risk." Risk analysis 42.9 (2022): 1999-2025.

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MAP
Map
Context is established and understood.

MAP 1.1
Intended purpose, potentially beneficial uses, context-specific laws, norms and
expectations, and prospective settings in which the AI system will be deployed are
understood and documented. Considerations include: specific set or types of users along
with their expectations; potential positive and negative impacts of system uses to
individuals, communities, organizations, society, and the planet; assumptions and related
limitations about AI system purposes; uses and risks across the development or product AI
lifecycle; TEVV and system metrics.

About
Highly accurate and optimized systems can cause harm. Relatedly, organizations should
expect broadly deployed AI tools to be reused, repurposed, and potentially misused
regardless of intentions.

AI actors can work collaboratively, and with external parties such as community groups, to
help delineate the bounds of acceptable deployment, consider preferable alternatives, and
identify principles and strategies to manage likely risks. Context mapping is the first step in
this effort, and may include examination of the following:

• intended purpose and impact of system use.


• concept of operations.
• intended, prospective, and actual deployment setting.
• requirements for system deployment and operation.
• end user and operator expectations.
• specific set or types of end users.
• potential negative impacts to individuals, groups, communities, organizations, and
society – or context-specific impacts such as legal requirements or impacts to the
environment.
• unanticipated, downstream, or other unknown contextual factors.
• how AI system changes connect to impacts.

These types of processes can assist AI actors in understanding how limitations, constraints,
and other realities associated with the deployment and use of AI technology can create
impacts once they are deployed or operate in the real world. When coupled with the
enhanced organizational culture resulting from the established policies and procedures in
the Govern function, the Map function can provide opportunities to foster and instill new
perspectives, activities, and skills for approaching risks and impacts.

Context mapping also includes discussion and consideration of non-AI or non-technology


alternatives especially as related to whether the given context is narrow enough to manage

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AI and its potential negative impacts. Non-AI alternatives may include capturing and
evaluating information using semi-autonomous or mostly-manual methods.

Suggested Actions
• Maintain awareness of industry, technical, and applicable legal standards.
• Examine trustworthiness of AI system design and consider, non-AI solutions
• Consider intended AI system design tasks along with unanticipated purposes in
collaboration with human factors and socio-technical domain experts.
• Define and document the task, purpose, minimum functionality, and benefits of the AI
system to inform considerations about whether the utility of the project or its lack of.
• Identify whether there are non-AI or non-technology alternatives that will lead to more
trustworthy outcomes.
• Examine how changes in system performance affect downstream events such as
decision-making (e.g: changes in an AI model objective function create what types of
impacts in how many candidates do/do not get a job interview).
• Determine actions to map and track post-decommissioning stages of AI deployment and
potential negative or positive impacts to individuals, groups and communities.
• Determine the end user and organizational requirements, including business and
technical requirements.
• Determine and delineate the expected and acceptable AI system context of use,
including:
• Perform context analysis related to time frame, safety concerns, geographic area,
physical environment, ecosystems, social environment, and cultural norms within the
intended setting (or conditions that closely approximate the intended setting.
• Gain and maintain awareness about evaluating scientific claims related to AI system
performance and benefits before launching into system design.
• Identify human-AI interaction and/or roles, such as whether the application will
support or replace human decision making.
• Plan for risks related to human-AI configurations, and document requirements, roles,
and responsibilities for human oversight of deployed systems.

Transparency & Documentation

Organizations can document the following


• To what extent is the output of each component appropriate for the operational
context?
• Which AI actors are responsible for the decisions of the AI and is this person aware of
the intended uses and limitations of the analytic?
• Which AI actors are responsible for maintaining, re-verifying, monitoring, and updating
this AI once deployed?
• Who is the person(s) accountable for the ethical considerations across the AI lifecycle?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities,

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• “Stakeholders in Explainable AI,” Sep. 2018.
• "Microsoft Responsible AI Standard, v2".

References

Socio-technical systems
Andrew D. Selbst, danah boyd, Sorelle A. Friedler, et al. 2019. Fairness and Abstraction in
Sociotechnical Systems. In Proceedings of the Conference on Fairness, Accountability, and
Transparency (FAccT'19). Association for Computing Machinery, New York, NY, USA, 59–68.

Problem formulation
Roel Dobbe, Thomas Krendl Gilbert, and Yonatan Mintz. 2021. Hard choices in artificial
intelligence. Artificial Intelligence 300 (14 July 2021), 103555, ISSN 0004-3702.

Samir Passi and Solon Barocas. 2019. Problem Formulation and Fairness. In Proceedings of
the Conference on Fairness, Accountability, and Transparency (FAccT'19). Association for
Computing Machinery, New York, NY, USA, 39–48.

Context mapping
Emilio Gómez-González and Emilia Gómez. 2020. Artificial intelligence in medicine and
healthcare. Joint Research Centre (European Commission).

Sarah Spiekermann and Till Winkler. 2020. Value-based Engineering for Ethics by Design.
arXiv:2004.13676.

Social Impact Lab. 2017. Framework for Context Analysis of Technologies in Social Change
Projects (Draft v2.0).

Solon Barocas, Asia J. Biega, Margarita Boyarskaya, et al. 2021. Responsible computing
during COVID-19 and beyond. Commun. ACM 64, 7 (July 2021), 30–32.

Identification of harms
Harini Suresh and John V. Guttag. 2020. A Framework for Understanding Sources of Harm
throughout the Machine Learning Life Cycle. arXiv:1901.10002.

Margarita Boyarskaya, Alexandra Olteanu, and Kate Crawford. 2020. Overcoming Failures of
Imagination in AI Infused System Development and Deployment. arXiv:2011.13416.

Microsoft. Foundations of assessing harm. 2022.

Understanding and documenting limitations in ML


Alexander D'Amour, Katherine Heller, Dan Moldovan, et al. 2020. Underspecification
Presents Challenges for Credibility in Modern Machine Learning. arXiv:2011.03395.

Arvind Narayanan. "How to Recognize AI Snake Oil." Arthur Miller Lecture on Science and
Ethics (2019).

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Jessie J. Smith, Saleema Amershi, Solon Barocas, et al. 2022. REAL ML: Recognizing,
Exploring, and Articulating Limitations of Machine Learning Research. arXiv:2205.08363.

Margaret Mitchell, Simone Wu, Andrew Zaldivar, et al. 2019. Model Cards for Model
Reporting. In Proceedings of the Conference on Fairness, Accountability, and Transparency
(FAT* '19). Association for Computing Machinery, New York, NY, USA, 220–229.

Matthew Arnold, Rachel K. E. Bellamy, Michael Hind, et al. 2019. FactSheets: Increasing
Trust in AI Services through Supplier's Declarations of Conformity. arXiv:1808.07261.

Matthew J. Salganik, Ian Lundberg, Alexander T. Kindel, Caitlin E. Ahearn, Khaled Al-
Ghoneim, Abdullah Almaatouq, Drew M. Altschul et al. "Measuring the Predictability of Life
Outcomes with a Scientific Mass Collaboration." Proceedings of the National Academy of
Sciences 117, No. 15 (2020): 8398-8403.

Michael A. Madaio, Luke Stark, Jennifer Wortman Vaughan, and Hanna Wallach. 2020. Co-
Designing Checklists to Understand Organizational Challenges and Opportunities around
Fairness in AI. In Proceedings of the 2020 CHI Conference on Human Factors in Computing
Systems (CHI ‘20). Association for Computing Machinery, New York, NY, USA, 1–14.

Timnit Gebru, Jamie Morgenstern, Briana Vecchione, et al. 2021. Datasheets for Datasets.
arXiv:1803.09010.

Bender, E. M., Friedman, B. & McMillan-Major, A., (2022). A Guide for Writing Data
Statements for Natural Language Processing. University of Washington. Accessed July 14,
2022.

Meta AI. System Cards, a new resource for understanding how AI systems work, 2021.

When not to deploy


Solon Barocas, Asia J. Biega, Benjamin Fish, et al. 2020. When not to design, build, or deploy.
In Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency (FAT*
'20). Association for Computing Machinery, New York, NY, USA, 695.

Post-decommission
Upol Ehsan, Ranjit Singh, Jacob Metcalf and Mark O. Riedl. “The Algorithmic Imprint.”
Proceedings of the 2022 ACM Conference on Fairness, Accountability, and Transparency
(2022).

Statistical balance
Ziad Obermeyer, Brian Powers, Christine Vogeli, and Sendhil Mullainathan. 2019. Dissecting
racial bias in an algorithm used to manage the health of populations. Science 366, 6464 (25
Oct. 2019), 447-453.

Assessment of science in AI
Arvind Narayanan. How to recognize AI snake oil.

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Emily M. Bender. 2022. On NYT Magazine on AI: Resist the Urge to be Impressed. (April 17,
2022).

MAP 1.2
Inter-disciplinary AI actors, competencies, skills and capacities for establishing context
reflect demographic diversity and broad domain and user experience expertise, and their
participation is documented. Opportunities for interdisciplinary collaboration are
prioritized.

About
Successfully mapping context requires a team of AI actors with a diversity of experience,
expertise, abilities and backgrounds, and with the resources and independence to engage in
critical inquiry.

Having a diverse team contributes to more broad and open sharing of ideas and
assumptions about the purpose and function of the technology being designed and
developed – making these implicit aspects more explicit. The benefit of a diverse staff in
managing AI risks is not the beliefs or presumed beliefs of individual workers, but the
behavior that results from a collective perspective. An environment which fosters critical
inquiry creates opportunities to surface problems and identify existing and emergent risks.

Suggested Actions
• Establish interdisciplinary teams to reflect a wide range of skills, competencies, and
capabilities for AI efforts. Verify that team membership includes demographic diversity,
broad domain expertise, and lived experiences. Document team composition.
• Create and empower interdisciplinary expert teams to capture, learn, and engage the
interdependencies of deployed AI systems and related terminologies and concepts from
disciplines outside of AI practice such as law, sociology, psychology, anthropology,
public policy, systems design, and engineering.

Transparency & Documentation

Organizations can document the following


• To what extent do the teams responsible for developing and maintaining the AI system
reflect diverse opinions, backgrounds, experiences, and perspectives?
• Did the entity document the demographics of those involved in the design and
development of the AI system to capture and communicate potential biases inherent to
the development process, according to forum participants?
• What specific perspectives did stakeholders share, and how were they integrated across
the design, development, deployment, assessment, and monitoring of the AI system?
• To what extent has the entity addressed stakeholder perspectives on the potential
negative impacts of the AI system on end users and impacted populations?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?

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• Did your organization address usability problems and test whether user interfaces
served their intended purposes? Consulting the community or end users at the earliest
stages of development to ensure there is transparency on the technology used and how
it is deployed.

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.

References
Sina Fazelpour and Maria De-Arteaga. 2022. Diversity in sociotechnical machine learning
systems. Big Data & Society 9, 1 (Jan. 2022).

Microsoft Community Jury , Azure Application Architecture Guide.

Fernando Delgado, Stephen Yang, Michael Madaio, Qian Yang. (2021). Stakeholder
Participation in AI: Beyond "Add Diverse Stakeholders and Stir".

Kush Varshney, Tina Park, Inioluwa Deborah Raji, Gaurush Hiranandani, Narasimhan
Harikrishna, Oluwasanmi Koyejo, Brianna Richardson, and Min Kyung Lee. Participatory
specification of trustworthy machine learning, 2021.

Donald Martin, Vinodkumar Prabhakaran, Jill A. Kuhlberg, Andrew Smart and William S.
Isaac. “Participatory Problem Formulation for Fairer Machine Learning Through
Community Based System Dynamics”, ArXiv abs/2005.07572 (2020).

MAP 1.3
The organization’s mission and relevant goals for the AI technology are understood and
documented.

About
Defining and documenting the specific business purpose of an AI system in a broader
context of societal values helps teams to evaluate risks and increases the clarity of “go/no-
go” decisions about whether to deploy.

Trustworthy AI technologies may present a demonstrable business benefit beyond implicit


or explicit costs, provide added value, and don't lead to wasted resources. Organizations can
feel confident in performing risk avoidance if the implicit or explicit risks outweigh the
advantages of AI systems, and not implementing an AI solution whose risks surpass
potential benefits.

For example, making AI systems more equitable can result in better managed risk, and can
help enhance consideration of the business value of making inclusively designed, accessible
and more equitable AI systems.

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Suggested Actions
• Build transparent practices into AI system development processes.
• Review the documented system purpose from a socio-technical perspective and in
consideration of societal values.
• Determine possible misalignment between societal values and stated organizational
principles and code of ethics.
• Flag latent incentives that may contribute to negative impacts.
• Evaluate AI system purpose in consideration of potential risks, societal values, and
stated organizational principles.

Transparency & Documentation

Organizations can document the following


• How does the AI system help the entity meet its goals and objectives?
• How do the technical specifications and requirements align with the AI system’s goals
and objectives?
• To what extent is the output appropriate for the operational context?

AI Transparency Resources
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI –
2019, [LINK](https://altai.insight-centre.org/),
• Including Insights from the Comptroller General’s Forum on the Oversight of Artificial
Intelligence An Accountability Framework for Federal Agencies and Other Entities,
2021,

References
M.S. Ackerman (2000). The Intellectual Challenge of CSCW: The Gap Between Social
Requirements and Technical Feasibility. Human–Computer Interaction, 15, 179 - 203.

McKane Andrus, Sarah Dean, Thomas Gilbert, Nathan Lambert, Tom Zick (2021). AI
Development for the Public Interest: From Abstraction Traps to Sociotechnical Risks.

Abeba Birhane, Pratyusha Kalluri, Dallas Card, et al. 2022. The Values Encoded in Machine
Learning Research. arXiv:2106.15590.

Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

Iason Gabriel, Artificial Intelligence, Values, and Alignment. Minds & Machines 30, 411–437
(2020).

PEAT “Business Case for Equitable AI”.

MAP 1.4
The business value or context of business use has been clearly defined or – in the case of
assessing existing AI systems – re-evaluated.

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About
Socio-technical AI risks emerge from the interplay between technical development
decisions and how a system is used, who operates it, and the social context into which it is
deployed. Addressing these risks is complex and requires a commitment to understanding
how contextual factors may interact with AI lifecycle actions. One such contextual factor is
how organizational mission and identified system purpose create incentives within AI
system design, development, and deployment tasks that may result in positive and negative
impacts. By establishing comprehensive and explicit enumeration of AI systems’ context of
of business use and expectations, organizations can identify and manage these types of
risks.

Suggested Actions
• Document business value or context of business use
• Reconcile documented concerns about the system’s purpose within the business context
of use compared to the organization’s stated values, mission statements, social
responsibility commitments, and AI principles.
• Reconsider the design, implementation strategy, or deployment of AI systems with
potential impacts that do not reflect institutional values.

Transparency & Documentation

Organizations can document the following


• What goals and objectives does the entity expect to achieve by designing, developing,
and/or deploying the AI system?
• To what extent are the system outputs consistent with the entity’s values and principles
to foster public trust and equity?
• To what extent are the metrics consistent with system goals, objectives, and constraints,
including ethical and compliance considerations?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• WEF Model AI Governance Framework Assessment 2020.

References
Algorithm Watch. AI Ethics Guidelines Global Inventory.

Ethical OS toolkit.

Emanuel Moss and Jacob Metcalf. 2020. Ethics Owners: A New Model of Organizational
Responsibility in Data-Driven Technology Companies. Data & Society Research Institute.

Future of Life Institute. Asilomar AI Principles.

Leonard Haas, Sebastian Gießler, and Veronika Thiel. 2020. In the realm of paper tigers –
exploring the failings of AI ethics guidelines. (April 28, 2020).

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MAP 1.5
Organizational risk tolerances are determined and documented.

About
Risk tolerance reflects the level and type of risk the organization is willing to accept while
conducting its mission and carrying out its strategy.

Organizations can follow existing regulations and guidelines for risk criteria, tolerance and
response established by organizational, domain, discipline, sector, or professional
requirements. Some sectors or industries may have established definitions of harm or may
have established documentation, reporting, and disclosure requirements.

Within sectors, risk management may depend on existing guidelines for specific
applications and use case settings. Where established guidelines do not exist, organizations
will want to define reasonable risk tolerance in consideration of different sources of risk
(e.g., financial, operational, safety and wellbeing, business, reputational, and model risks)
and different levels of risk (e.g., from negligible to critical).

Risk tolerances inform and support decisions about whether to continue with development
or deployment - termed “go/no-go”. Go/no-go decisions related to AI system risks can take
stakeholder feedback into account, but remain independent from stakeholders’ vested
financial or reputational interests.

If mapping risk is prohibitively difficult, a "no-go" decision may be considered for the
specific system.

Suggested Actions
• Utilize existing regulations and guidelines for risk criteria, tolerance and response
established by organizational, domain, discipline, sector, or professional requirements.
• Establish risk tolerance levels for AI systems and allocate the appropriate oversight
resources to each level.
• Establish risk criteria in consideration of different sources of risk, (e.g., financial,
operational, safety and wellbeing, business, reputational, and model risks) and different
levels of risk (e.g., from negligible to critical).
• Identify maximum allowable risk tolerance above which the system will not be
deployed, or will need to be prematurely decommissioned, within the contextual or
application setting.
• Articulate and analyze tradeoffs across trustworthiness characteristics as relevant to
proposed context of use. When tradeoffs arise, document them and plan for traceable
actions (e.g.: impact mitigation, removal of system from development or use) to inform
management decisions.
• Review uses of AI systems for “off-label” purposes, especially in settings that
organizations have deemed as high-risk. Document decisions, risk-related trade-offs,
and system limitations.

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Transparency & Documentation

Organizations can document the following


• Which existing regulations and guidelines apply, and the entity has followed, in the
development of system risk tolerances?
• What criteria and assumptions has the entity utilized when developing system risk
tolerances?
• How has the entity identified maximum allowable risk tolerance?
• What conditions and purposes are considered “off-label” for system use?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.

References
Board of Governors of the Federal Reserve System. SR 11-7: Guidance on Model Risk
Management. (April 4, 2011).

The Office of the Comptroller of the Currency. Enterprise Risk Appetite Statement. (Nov. 20,
2019).

Brenda Boultwood, How to Develop an Enterprise Risk-Rating Approach (Aug. 26, 2021).
Global Association of Risk Professionals (garp.org). Accessed Jan. 4, 2023.

Virginia Eubanks, 1972-, Automating Inequality: How High-tech Tools Profile, Police, and
Punish the Poor. New York, NY, St. Martin's Press, 2018.

GAO-17-63: Enterprise Risk Management: Selected Agencies’ Experiences Illustrate Good


Practices in Managing Risk.

NIST Risk Management Framework.

MAP 1.6
System requirements (e.g., “the system shall respect the privacy of its users”) are elicited
from and understood by relevant AI actors. Design decisions take socio-technical
implications into account to address AI risks.

About
AI system development requirements may outpace documentation processes for traditional
software. When written requirements are unavailable or incomplete, AI actors may
inadvertently overlook business and stakeholder needs, over-rely on implicit human biases
such as confirmation bias and groupthink, and maintain exclusive focus on computational
requirements.

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Eliciting system requirements, designing for end users, and considering societal impacts
early in the design phase is a priority that can enhance AI systems’ trustworthiness.

Suggested Actions
• Proactively incorporate trustworthy characteristics into system requirements.
• Establish mechanisms for regular communication and feedback between relevant AI
actors and internal or external stakeholders related to system design or deployment
decisions.
• Develop and standardize practices to assess potential impacts at all stages of the AI
lifecycle, and in collaboration with interdisciplinary experts, actors external to the team
that developed or deployed the AI system, and potentially impacted communities .
• Include potentially impacted groups, communities and external entities (e.g. civil society
organizations, research institutes, local community groups, and trade associations) in
the formulation of priorities, definitions and outcomes during impact assessment
activities.
• Conduct qualitative interviews with end user(s) to regularly evaluate expectations and
design plans related to Human-AI configurations and tasks.
• Analyze dependencies between contextual factors and system requirements. List
potential impacts that may arise from not fully considering the importance of
trustworthiness characteristics in any decision making.
• Follow responsible design techniques in tasks such as software engineering, product
management, and participatory engagement. Some examples for eliciting and
documenting stakeholder requirements include product requirement documents
(PRDs), user stories, user interaction/user experience (UI/UX) research, systems
engineering, ethnography and related field methods.
• Conduct user research to understand individuals, groups and communities that will be
impacted by the AI, their values & context, and the role of systemic and historical biases.
Integrate learnings into decisions about data selection and representation.

Transparency & Documentation

Organizations can document the following


• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?
• To what extent is this information sufficient and appropriate to promote transparency?
Promote transparency by enabling external stakeholders to access information on the
design, operation, and limitations of the AI system.
• To what extent has relevant information been disclosed regarding the use of AI systems,
such as (a) what the system is for, (b) what it is not for, (c) how it was designed, and (d)
what its limitations are? (Documentation and external communication can offer a way
for entities to provide transparency.)

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• How will the relevant AI actor(s) address changes in accuracy and precision due to
either an adversary’s attempts to disrupt the AI system or unrelated changes in the
operational/business environment, which may impact the accuracy of the AI system?
• What metrics has the entity developed to measure performance of the AI system?
• What justifications, if any, has the entity provided for the assumptions, boundaries, and
limitations of the AI system?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Stakeholders in Explainable AI, Sep. 2018.
• High-Level Expert Group on Artificial Intelligence set up by the European Commission,
Ethics Guidelines for Trustworthy AI.

References
National Academies of Sciences, Engineering, and Medicine 2022. Fostering Responsible
Computing Research: Foundations and Practices. Washington, DC: The National Academies
Press.

Abeba Birhane, William S. Isaac, Vinodkumar Prabhakaran, Mark Diaz, Madeleine Clare
Elish, Iason Gabriel and Shakir Mohamed. “Power to the People? Opportunities and
Challenges for Participatory AI.” Equity and Access in Algorithms, Mechanisms, and
Optimization (2022).

Amit K. Chopra, Fabiano Dalpiaz, F. Başak Aydemir, et al. 2014. Protos: Foundations for
engineering innovative sociotechnical systems. In 2014 IEEE 22nd International
Requirements Engineering Conference (RE) (2014), 53-62.

Andrew D. Selbst, danah boyd, Sorelle A. Friedler, et al. 2019. Fairness and Abstraction in
Sociotechnical Systems. In Proceedings of the Conference on Fairness, Accountability, and
Transparency (FAT* '19). Association for Computing Machinery, New York, NY, USA, 59–68.

Gordon Baxter and Ian Sommerville. 2011. Socio-technical systems: From design methods
to systems engineering. Interacting with Computers, 23, 1 (Jan. 2011), 4–17.

Roel Dobbe, Thomas Krendl Gilbert, and Yonatan Mintz. 2021. Hard choices in artificial
intelligence. Artificial Intelligence 300 (14 July 2021), 103555, ISSN 0004-3702.

Yilin Huang, Giacomo Poderi, Sanja Šćepanović, et al. 2019. Embedding Internet-of-Things in
Large-Scale Socio-technical Systems: A Community-Oriented Design in Future Smart Grids.
In The Internet of Things for Smart Urban Ecosystems (2019), 125-150. Springer, Cham.

Victor Udoewa, (2022). An introduction to radical participatory design: decolonising


participatory design processes. Design Science. 8. 10.1017/dsj.2022.24.

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MAP 2.1
The specific task, and methods used to implement the task, that the AI system will support
is defined (e.g., classifiers, generative models, recommenders).

About
AI actors define the technical learning or decision-making task(s) an AI system is designed
to accomplish, or the benefits that the system will provide. The clearer and narrower the
task definition, the easier it is to map its benefits and risks, leading to more fulsome risk
management.

Suggested Actions
• Define and document AI system’s existing and potential learning task(s) along with
known assumptions and limitations.

Transparency & Documentation

Organizations can document the following


• To what extent has the entity clearly defined technical specifications and requirements
for the AI system?
• To what extent has the entity documented the AI system’s development, testing
methodology, metrics, and performance outcomes?
• How do the technical specifications and requirements align with the AI system’s goals
and objectives?
• Did your organization implement accountability-based practices in data management
and protection (e.g. the PDPA and OECD Privacy Principles)?
• How are outputs marked to clearly show that they came from an AI?

AI Transparency Resources
• Datasheets for Datasets.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• ATARC Model Transparency Assessment (WD) – 2020.
• Transparency in Artificial Intelligence - S. Larsson and F. Heintz – 2020.

References
Leong, Brenda (2020). The Spectrum of Artificial Intelligence - An Infographic Tool. Future
of Privacy Forum.

Brownlee, Jason (2020). A Tour of Machine Learning Algorithms. Machine Learning


Mastery.

MAP 2.2
Information about the AI system’s knowledge limits and how system output may be utilized
and overseen by humans is documented. Documentation provides sufficient information to
assist relevant AI actors when making informed decisions and taking subsequent actions.

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About
An AI lifecycle consists of many interdependent activities involving a diverse set of actors
that often do not have full visibility or control over other parts of the lifecycle and its
associated contexts or risks. The interdependencies between these activities, and among the
relevant AI actors and organizations, can make it difficult to reliably anticipate potential
impacts of AI systems. For example, early decisions in identifying the purpose and objective
of an AI system can alter its behavior and capabilities, and the dynamics of deployment
setting (such as end users or impacted individuals) can shape the positive or negative
impacts of AI system decisions. As a result, the best intentions within one dimension of the
AI lifecycle can be undermined via interactions with decisions and conditions in other, later
activities. This complexity and varying levels of visibility can introduce uncertainty. And,
once deployed and in use, AI systems may sometimes perform poorly, manifest
unanticipated negative impacts, or violate legal or ethical norms. These risks and incidents
can result from a variety of factors. For example, downstream decisions can be influenced
by end user over-trust or under-trust, and other complexities related to AI-supported
decision-making.

Anticipating, articulating, assessing and documenting AI systems’ knowledge limits and how
system output may be utilized and overseen by humans can help mitigate the uncertainty
associated with the realities of AI system deployments. Rigorous design processes include
defining system knowledge limits, which are confirmed and refined based on TEVV
processes.

Suggested Actions
• Document settings, environments and conditions that are outside the AI system’s
intended use.
• Design for end user workflows and toolsets, concept of operations, and explainability
and interpretability criteria in conjunction with end user(s) and associated qualitative
feedback.
• Plan and test human-AI configurations under close to real-world conditions and
document results.
• Follow stakeholder feedback processes to determine whether a system achieved its
documented purpose within a given use context, and whether end users can correctly
comprehend system outputs or results.
• Document dependencies on upstream data and other AI systems, including if the
specified system is an upstream dependency for another AI system or other data.
• Document connections the AI system or data will have to external networks (including
the internet), financial markets, and critical infrastructure that have potential for
negative externalities. Identify and document negative impacts as part of considering
the broader risk thresholds and subsequent go/no-go deployment as well as post-
deployment decommissioning decisions.

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Transparency & Documentation

Organizations can document the following


• Does the AI system provide sufficient information to assist the personnel to make an
informed decision and take actions accordingly?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?
• Based on the assessment, did your organization implement the appropriate level of
human involvement in AI-augmented decision-making?

AI Transparency Resources
• Datasheets for Datasets.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• ATARC Model Transparency Assessment (WD) – 2020.
• Transparency in Artificial Intelligence - S. Larsson and F. Heintz – 2020.

References

Context of use
International Standards Organization (ISO). 2019. ISO 9241-210:2019 Ergonomics of
human-system interaction — Part 210: Human-centred design for interactive systems.

National Institute of Standards and Technology (NIST), Mary Theofanos, Yee-Yin Choong, et
al. 2017. NIST Handbook 161 Usability Handbook for Public Safety Communications:
Ensuring Successful Systems for First Responders.

Human-AI interaction
Committee on Human-System Integration Research Topics for the 711th Human
Performance Wing of the Air Force Research Laboratory and the National Academies of
Sciences, Engineering, and Medicine. 2022. Human-AI Teaming: State-of-the-Art and
Research Needs. Washington, D.C. National Academies Press.

Human Readiness Level Scale in the System Development Process, American National
Standards Institute and Human Factors and Ergonomics Society, ANSI/HFES 400-2021

Microsoft Responsible AI Standard, v2.

Saar Alon-Barkat, Madalina Busuioc, Human–AI Interactions in Public Sector Decision


Making: “Automation Bias” and “Selective Adherence” to Algorithmic Advice, Journal of
Public Administration Research and Theory, 2022;, muac007.

Zana Buçinca, Maja Barbara Malaya, and Krzysztof Z. Gajos. 2021. To Trust or to Think:
Cognitive Forcing Functions Can Reduce Overreliance on AI in AI-assisted Decision-making.
Proc. ACM Hum.-Comput. Interact. 5, CSCW1, Article 188 (April 2021), 21 pages.

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Mary L. Cummings. 2006 Automation and accountability in decision support system
interface design.The Journal of Technology Studies 32(1): 23–31.

Engstrom, D. F., Ho, D. E., Sharkey, C. M., & Cuéllar, M. F. (2020). Government by algorithm:
Artificial intelligence in federal administrative agencies. NYU School of Law, Public Law
Research Paper, (20-54).

Susanne Gaube, Harini Suresh, Martina Raue, et al. 2021. Do as AI say: susceptibility in
deployment of clinical decision-aids. npj Digital Medicine 4, Article 31 (2021).

Ben Green. 2021. The Flaws of Policies Requiring Human Oversight of Government
Algorithms. Computer Law & Security Review 45 (26 Apr. 2021).

Ben Green and Amba Kak. 2021. The False Comfort of Human Oversight as an Antidote to
A.I. Harm. (June 15, 2021).

Grgić-Hlača, N., Engel, C., & Gummadi, K. P. (2019). Human decision making with machine
assistance: An experiment on bailing and jailing. Proceedings of the ACM on Human-
Computer Interaction, 3(CSCW), 1-25.

Forough Poursabzi-Sangdeh, Daniel G Goldstein, Jake M Hofman, et al. 2021. Manipulating


and Measuring Model Interpretability. In Proceedings of the 2021 CHI Conference on
Human Factors in Computing Systems (CHI '21). Association for Computing Machinery, New
York, NY, USA, Article 237, 1–52.

C. J. Smith (2019). Designing trustworthy AI: A human-machine teaming framework to


guide development. arXiv preprint arXiv:1910.03515.

T. Warden, P. Carayon, EM et al. The National Academies Board on Human System


Integration (BOHSI) Panel: Explainable AI, System Transparency, and Human Machine
Teaming. Proceedings of the Human Factors and Ergonomics Society Annual Meeting.
2019;63(1):631-635. doi:10.1177/1071181319631100.

MAP 2.3
Scientific integrity and TEVV considerations are identified and documented, including those
related to experimental design, data collection and selection (e.g., availability,
representativeness, suitability), system trustworthiness, and construct validation.

About
Standard testing and evaluation protocols provide a basis to confirm assurance in a system
that it is operating as designed and claimed. AI systems’ complexities create challenges for
traditional testing and evaluation methodologies, which tend to be designed for static or
isolated system performance. Opportunities for risk continue well beyond design and
deployment, into system operation and application of system-enabled decisions. Testing
and evaluation methodologies and metrics therefore address a continuum of activities.

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TEVV is enhanced when key metrics for performance, safety, and reliability are interpreted
in a socio-technical context and not confined to the boundaries of the AI system pipeline.

Other challenges for managing AI risks relate to dependence on large scale datasets, which
can impact data quality and validity concerns. The difficulty of finding the “right” data may
lead AI actors to select datasets based more on accessibility and availability than on
suitability for operationalizing the phenomenon that the AI system intends to support or
inform. Such decisions could contribute to an environment where the data used in
processes is not fully representative of the populations or phenomena that are being
modeled, introducing downstream risks. Practices such as dataset reuse may also lead to
disconnect from the social contexts and time periods of their creation. This contributes to
issues of validity of the underlying dataset for providing proxies, measures, or predictors
within the model.

Suggested Actions
• Identify and document experiment design and statistical techniques that are valid for
testing complex socio-technical systems like AI, which involve human factors, emergent
properties, and dynamic context(s) of use.
• Develop and apply TEVV protocols for models, system and its subcomponents,
deployment, and operation.
• Demonstrate and document that AI system performance and validation metrics are
interpretable and unambiguous for downstream decision making tasks, and take socio-
technical factors such as context of use into consideration.
• Identify and document assumptions, techniques, and metrics used for testing and
evaluation throughout the AI lifecycle including experimental design techniques for data
collection, selection, and management practices in accordance with data governance
policies established in GOVERN.
• Identify testing modules that can be incorporated throughout the AI lifecycle, and verify
that processes enable corroboration by independent evaluators.
• Establish mechanisms for regular communication and feedback among relevant AI
actors and internal or external stakeholders related to the validity of design and
deployment assumptions.
• Establish mechanisms for regular communication and feedback between relevant AI
actors and internal or external stakeholders related to the development of TEVV
approaches throughout the lifecycle to detect and assess potentially harmful impacts
• Document assumptions made and techniques used in data selection, curation,
preparation and analysis, including:
• Map adherence to policies that address data and construct validity, bias, privacy and
security for AI systems and verify documentation, oversight, and processes.
• Identify and document transparent methods (e.g. causal discovery methods) for
inferring causal relationships between constructs being modeled and dataset attributes
or proxies.

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• Identify and document processes to understand and trace test and training data lineage
and its metadata resources for mapping risks.
• Document known limitations, risk mitigation efforts associated with, and methods used
for, training data collection, selection, labeling, cleaning, and analysis (e.g. treatment of
missing, spurious, or outlier data; biased estimators).
• Establish and document practices to check for capabilities that are in excess of those
that are planned for, such as emergent properties, and to revisit prior risk management
steps in light of any new capabilities.
• Establish processes to test and verify that design assumptions about the set of
deployment contexts continue to be accurate and sufficiently complete.
• Work with domain experts and other external AI actors to:
• Investigate and document potential negative impacts due related to the full product
lifecycle and associated processes that may conflict with organizational values and
principles.

Transparency & Documentation

Organizations can document the following


• Are there any known errors, sources of noise, or redundancies in the data?
• Over what time-frame was the data collected? Does the collection time-frame match the
creation time-frame
• What is the variable selection and evaluation process?
• How was the data collected? Who was involved in the data collection process? If the
dataset relates to people (e.g., their attributes) or was generated by people, were they
informed about the data collection? (e.g., datasets that collect writing, photos,
interactions, transactions, etc.)
• As time passes and conditions change, is the training data still representative of the
operational environment?
• Why was the dataset created? (e.g., were there specific tasks in mind, or a specific gap
that needed to be filled?)
• How does the entity ensure that the data collected are adequate, relevant, and not
excessive in relation to the intended purpose?

AI Transparency Resources
• Datasheets for Datasets.
• WEF Model AI Governance Framework Assessment 2020.
• WEF Companion to the Model AI Governance Framework- 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• ATARC Model Transparency Assessment (WD) – 2020.
• Transparency in Artificial Intelligence - S. Larsson and F. Heintz – 2020.

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References

Challenges with dataset selection


Alexandra Olteanu, Carlos Castillo, Fernando Diaz, and Emre Kiciman. 2019. Social Data:
Biases, Methodological Pitfalls, and Ethical Boundaries. Front. Big Data 2, 13 (11 July 2019).

Amandalynne Paullada, Inioluwa Deborah Raji, Emily M. Bender, et al. 2020. Data and its
(dis)contents: A survey of dataset development and use in machine learning research.
arXiv:2012.05345.

Catherine D'Ignazio and Lauren F. Klein. 2020. Data Feminism. The MIT Press, Cambridge,
MA.

Miceli, M., & Posada, J. (2022). The Data-Production Dispositif. ArXiv, abs/2205.11963.

Barbara Plank. 2016. What to do about non-standard (or non-canonical) language in NLP.
arXiv:1608.07836.

Dataset and test, evaluation, validation and verification (TEVV) processes in AI system
development
National Institute of Standards and Technology (NIST), Reva Schwartz, Apostol Vassilev, et
al. 2022. NIST Special Publication 1270 Towards a Standard for Identifying and Managing
Bias in Artificial Intelligence.

Inioluwa Deborah Raji, Emily M. Bender, Amandalynne Paullada, et al. 2021. AI and the
Everything in the Whole Wide World Benchmark. arXiv:2111.15366.

Statistical balance
Ziad Obermeyer, Brian Powers, Christine Vogeli, and Sendhil Mullainathan. 2019. Dissecting
racial bias in an algorithm used to manage the health of populations. Science 366, 6464 (25
Oct. 2019), 447-453.

Amandalynne Paullada, Inioluwa Deborah Raji, Emily M. Bender, et al. 2020. Data and its
(dis)contents: A survey of dataset development and use in machine learning research.
arXiv:2012.05345.

Solon Barocas, Anhong Guo, Ece Kamar, et al. 2021. Designing Disaggregated Evaluations of
AI Systems: Choices, Considerations, and Tradeoffs. Proceedings of the 2021 AAAI/ACM
Conference on AI, Ethics, and Society. Association for Computing Machinery, New York, NY,
USA, 368–378.

Measurement and evaluation


Abigail Z. Jacobs and Hanna Wallach. 2021. Measurement and Fairness. In Proceedings of
the 2021 ACM Conference on Fairness, Accountability, and Transparency (FAccT ‘21).
Association for Computing Machinery, New York, NY, USA, 375–385.

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Ben Hutchinson, Negar Rostamzadeh, Christina Greer, et al. 2022. Evaluation Gaps in
Machine Learning Practice. arXiv:2205.05256.

Laura Freeman, "Test and evaluation for artificial intelligence." Insight 23.1 (2020): 27-30.

Existing frameworks
National Institute of Standards and Technology. (2018). Framework for improving critical
infrastructure cybersecurity.

Kaitlin R. Boeckl and Naomi B. Lefkovitz. "NIST Privacy Framework: A Tool for Improving
Privacy Through Enterprise Risk Management, Version 1.0." National Institute of Standards
and Technology (NIST), January 16, 2020.

MAP 3.1
Potential benefits of intended AI system functionality and performance are examined and
documented.

About
AI systems have enormous potential to improve quality of life, enhance economic prosperity
and security costs. Organizations are encouraged to define and document system purpose
and utility, and its potential positive impacts and benefits beyond current known
performance benchmarks.

It is encouraged that risk management and assessment of benefits and impacts include
processes for regular and meaningful communication with potentially affected groups and
communities. These stakeholders can provide valuable input related to systems’ benefits
and possible limitations. Organizations may differ in the types and number of stakeholders
with which they engage.

Other approaches such as human-centered design (HCD) and value-sensitive design (VSD)
can help AI teams to engage broadly with individuals and communities. This type of
engagement can enable AI teams to learn about how a given technology may cause positive
or negative impacts, that were not originally considered or intended.

Suggested Actions
• Utilize participatory approaches and engage with system end users to understand and
document AI systems’ potential benefits, efficacy and interpretability of AI task output.
• Maintain awareness and documentation of the individuals, groups, or communities who
make up the system’s internal and external stakeholders.
• Verify that appropriate skills and practices are available in-house for carrying out
participatory activities such as eliciting, capturing, and synthesizing user, operator and
external feedback, and translating it for AI design and development functions.
• Establish mechanisms for regular communication and feedback between relevant AI
actors and internal or external stakeholders related to system design or deployment
decisions.

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• Consider performance to human baseline metrics or other standard benchmarks.
• Incorporate feedback from end users, and potentially impacted individuals and
communities about perceived system benefits .

Transparency & Documentation

Organizations can document the following


• Have the benefits of the AI system been communicated to end users?
• Have the appropriate training material and disclaimers about how to adequately use the
AI system been provided to end users?
• Has your organization implemented a risk management system to address risks
involved in deploying the identified AI system (e.g. personnel risk or changes to
commercial objectives)?

AI Transparency Resources
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI –
2019. [LINK](https://altai.insight-centre.org/),

References
Roel Dobbe, Thomas Krendl Gilbert, and Yonatan Mintz. 2021. Hard choices in artificial
intelligence. Artificial Intelligence 300 (14 July 2021), 103555, ISSN 0004-3702.

Samir Passi and Solon Barocas. 2019. Problem Formulation and Fairness. In Proceedings of
the Conference on Fairness, Accountability, and Transparency (FAT* '19). Association for
Computing Machinery, New York, NY, USA, 39–48.

Vincent T. Covello. 2021. Stakeholder Engagement and Empowerment. In Communicating in


Risk, Crisis, and High Stress Situations (Vincent T. Covello, ed.), 87-109.

Yilin Huang, Giacomo Poderi, Sanja Šćepanović, et al. 2019. Embedding Internet-of-Things in
Large-Scale Socio-technical Systems: A Community-Oriented Design in Future Smart Grids.
In The Internet of Things for Smart Urban Ecosystems (2019), 125-150. Springer, Cham.

Eloise Taysom and Nathan Crilly. 2017. Resilience in Sociotechnical Systems: The
Perspectives of Multiple Stakeholders. She Ji: The Journal of Design, Economics, and
Innovation, 3, 3 (2017), 165-182, ISSN 2405-8726.

MAP 3.2
Potential costs, including non-monetary costs, which result from expected or realized AI
errors or system functionality and trustworthiness - as connected to organizational risk
tolerance - are examined and documented.

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About
Anticipating negative impacts of AI systems is a difficult task. Negative impacts can be due
to many factors, such as system non-functionality or use outside of its operational limits,
and may range from minor annoyance to serious injury, financial losses, or regulatory
enforcement actions. AI actors can work with a broad set of stakeholders to improve their
capacity for understanding systems’ potential impacts – and subsequently – systems’ risks.

Suggested Actions
• Perform context analysis to map potential negative impacts arising from not integrating
trustworthiness characteristics. When negative impacts are not direct or obvious, AI
actors can engage with stakeholders external to the team that developed or deployed
the AI system, and potentially impacted communities, to examine and document:
• Identify and implement procedures for regularly evaluating the qualitative and
quantitative costs of internal and external AI system failures. Develop actions to
prevent, detect, and/or correct potential risks and related impacts. Regularly evaluate
failure costs to inform go/no-go deployment decisions throughout the AI system
lifecycle.

Transparency & Documentation

Organizations can document the following


• To what extent does the system/entity consistently measure progress towards stated
goals and objectives?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• Have you documented and explained that machine errors may differ from human
errors?

AI Transparency Resources
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI –
2019. [LINK](https://altai.insight-centre.org/),

References
Abagayle Lee Blank. 2019. Computer vision machine learning and future-oriented ethics.
Honors Project. Seattle Pacific University (SPU), Seattle, WA.

Margarita Boyarskaya, Alexandra Olteanu, and Kate Crawford. 2020. Overcoming Failures of
Imagination in AI Infused System Development and Deployment. arXiv:2011.13416.

Jeff Patton. 2014. User Story Mapping. O'Reilly, Sebastopol, CA.

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Margarita Boenig-Liptsin, Anissa Tanweer & Ari Edmundson (2022) Data Science Ethos
Lifecycle: Interplay of ethical thinking and data science practice, Journal of Statistics and
Data Science Education, DOI: 10.1080/26939169.2022.2089411

J. Cohen, D. S. Katz, M. Barker, N. Chue Hong, R. Haines and C. Jay, "The Four Pillars of
Research Software Engineering," in IEEE Software, vol. 38, no. 1, pp. 97-105, Jan.-Feb. 2021,
doi: 10.1109/MS.2020.2973362.

National Academies of Sciences, Engineering, and Medicine 2022. Fostering Responsible


Computing Research: Foundations and Practices. Washington, DC: The National Academies
Press.

MAP 3.3
Targeted application scope is specified and documented based on the system’s capability,
established context, and AI system categorization.

About
Systems that function in a narrow scope tend to enable better mapping, measurement, and
management of risks in the learning or decision-making tasks and the system context. A
narrow application scope also helps ease TEVV functions and related resources within an
organization.

For example, large language models or open-ended chatbot systems that interact with the
public on the internet have a large number of risks that may be difficult to map, measure,
and manage due to the variability from both the decision-making task and the operational
context. Instead, a task-specific chatbot utilizing templated responses that follow a defined
“user journey” is a scope that can be more easily mapped, measured and managed.

Suggested Actions
• Consider narrowing contexts for system deployment, including factors related to:

• How outcomes may directly or indirectly affect users, groups, communities and
the environment.
• Length of time the system is deployed in between re-trainings.
• Geographical regions in which the system operates.
• Dynamics related to community standards or likelihood of system misuse or
abuses (either purposeful or unanticipated).
• How AI system features and capabilities can be utilized within other
applications, or in place of other existing processes.

• Engage AI actors from legal and procurement functions when specifying target
application scope.

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Transparency & Documentation

Organizations can document the following


• To what extent has the entity clearly defined technical specifications and requirements
for the AI system?
• How do the technical specifications and requirements align with the AI system’s goals
and objectives?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI –
2019. [LINK](https://altai.insight-centre.org/),

References
Mark J. Van der Laan and Sherri Rose (2018). Targeted Learning in Data Science. Cham:
Springer International Publishing, 2018.

Alice Zheng. 2015. Evaluating Machine Learning Models (2015). O'Reilly.

Brenda Leong and Patrick Hall (2021). 5 things lawyers should know about artificial
intelligence. ABA Journal.

UK Centre for Data Ethics and Innovation, “The roadmap to an effective AI assurance
ecosystem”.

MAP 3.4
Processes for operator and practitioner proficiency with AI system performance and
trustworthiness – and relevant technical standards and certifications – are defined,
assessed and documented.

About
Human-AI configurations can span from fully autonomous to fully manual. AI systems can
autonomously make decisions, defer decision-making to a human expert, or be used by a
human decision-maker as an additional opinion. In some scenarios, professionals with
expertise in a specific domain work in conjunction with an AI system towards a specific end
goal—for example, a decision about another individual(s). Depending on the purpose of the
system, the expert may interact with the AI system but is rarely part of the design or
development of the system itself. These experts are not necessarily familiar with machine
learning, data science, computer science, or other fields traditionally associated with AI
design or development and - depending on the application - will likely not require such
familiarity. For example, for AI systems that are deployed in health care delivery the experts
are the physicians and bring their expertise about medicine—not data science, data
modeling and engineering, or other computational factors. The challenge in these settings is
not educating the end user about AI system capabilities, but rather leveraging, and not
replacing, practitioner domain expertise.

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Questions remain about how to configure humans and automation for managing AI risks.
Risk management is enhanced when organizations that design, develop or deploy AI
systems for use by professional operators and practitioners:

• are aware of these knowledge limitations and strive to identify risks in human-AI
interactions and configurations across all contexts, and the potential resulting impacts,
• define and differentiate the various human roles and responsibilities when using or
interacting with AI systems, and
• determine proficiency standards for AI system operation in proposed context of use, as
enumerated in MAP-1 and established in GOVERN-3.2.

Suggested Actions
• Identify and declare AI system features and capabilities that may affect downstream AI
actors’ decision-making in deployment and operational settings for example how
system features and capabilities may activate known risks in various human-AI
configurations, such as selective adherence.
• Identify skills and proficiency requirements for operators, practitioners and other
domain experts that interact with AI systems,Develop AI system operational
documentation for AI actors in deployed and operational environments, including
information about known risks, mitigation criteria, and trustworthy characteristics
enumerated in Map-1.
• Define and develop training materials for proposed end users, practitioners and
operators about AI system use and known limitations.
• Define and develop certification procedures for operating AI systems within defined
contexts of use, and information about what exceeds operational boundaries.
• Include operators, practitioners and end users in AI system prototyping and testing
activities to help inform operational boundaries and acceptable performance. Conduct
testing activities under scenarios similar to deployment conditions.
• Verify model output provided to AI system operators, practitioners and end users is
interactive, and specified to context and user requirements defined in MAP-1.
• Verify AI system output is interpretable and unambiguous for downstream decision
making tasks.
• Design AI system explanation complexity to match the level of problem and context
complexity.
• Verify that design principles are in place for safe operation by AI actors in decision-
making environments.
• Develop approaches to track human-AI configurations, operator, and practitioner
outcomes for integration into continual improvement.

Transparency & Documentation

Organizations can document the following


• What policies has the entity developed to ensure the use of the AI system is consistent
with its stated values and principles?

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• How will the accountable human(s) address changes in accuracy and precision due to
either an adversary’s attempts to disrupt the AI or unrelated changes in
operational/business environment, which may impact the accuracy of the AI?
• How does the entity assess whether personnel have the necessary skills, training,
resources, and domain knowledge to fulfill their assigned responsibilities?
• Are the relevant staff dealing with AI systems properly trained to interpret AI model
output and decisions as well as to detect and manage bias in data?
• What metrics has the entity developed to measure performance of various components?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• WEF Companion to the Model AI Governance Framework- 2020.

References
National Academies of Sciences, Engineering, and Medicine. 2022. Human-AI Teaming:

State-of-the-Art and Research Needs. Washington, DC: The National Academies Press.

Human Readiness Level Scale in the System Development Process, American National
Standards Institute and Human Factors and Ergonomics Society, ANSI/HFES 400-2021.

Human-Machine Teaming Systems Engineering Guide. P McDermott, C Dominguez, N


Kasdaglis, M Ryan, I Trahan, A Nelson. MITRE Corporation, 2018.

Saar Alon-Barkat, Madalina Busuioc, Human–AI Interactions in Public Sector Decision


Making: “Automation Bias” and “Selective Adherence” to Algorithmic Advice, Journal of
Public Administration Research and Theory, 2022;, muac007.

Breana M. Carter-Browne, Susannah B. F. Paletz, Susan G. Campbell , Melissa J. Carraway,


Sarah H. Vahlkamp, Jana Schwartz , Polly O’Rourke, “There is No “AI” in Teams: A
Multidisciplinary Framework for AIs to Work in Human Teams; Applied Research
Laboratory for Intelligence and Security (ARLIS) Report, June 2021.

R Crootof, ME Kaminski, and WN Price II. Humans in the Loop (March 25, 2022). Vanderbilt
Law Review, Forthcoming 2023, U of Colorado Law Legal Studies Research Paper No. 22-10,
U of Michigan Public Law Research Paper No. 22-011.

S Mo Jones-Jang, Yong Jin Park, How do people react to AI failure? Automation bias,
algorithmic aversion, and perceived controllability, Journal of Computer-Mediated
Communication, Volume 28, Issue 1, January 2023, zmac029.

A Knack, R Carter and A Babuta, "Human-Machine Teaming in Intelligence Analysis:


Requirements for developing trust in machine learning systems," CETaS Research Reports
(December 2022).

SD Ramchurn, S Stein , NR Jennings. Trustworthy human-AI partnerships. iScience.


2021;24(8):102891. Published 2021 Jul 24. doi:10.1016/j.isci.2021.102891.

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M. Veale, M. Van Kleek, and R. Binns, “Fairness and Accountability Design Needs for
Algorithmic Support in High-Stakes Public Sector Decision-Making,” in Proceedings of the
2018 CHI Conference on Human Factors in Computing Systems - CHI ’18. Montreal QC,
Canada: ACM Press, 2018, pp. 1–14.

MAP 3.5
Processes for human oversight are defined, assessed, and documented in accordance with
organizational policies from GOVERN function.

About
As AI systems have evolved in accuracy and precision, computational systems have moved
from being used purely for decision support—or for explicit use by and under the

control of a human operator—to automated decision making with limited input from
humans. Computational decision support systems augment another, typically human,
system in making decisions.These types of configurations increase the likelihood of outputs
being produced with little human involvement.

Defining and differentiating various human roles and responsibilities for AI systems’
governance, and differentiating AI system overseers and those using or interacting with AI
systems can enhance AI risk management activities.

In critical systems, high-stakes settings, and systems deemed high-risk it is of vital


importance to evaluate risks and effectiveness of oversight procedures before an AI system
is deployed.

Ultimately, AI system oversight is a shared responsibility, and attempts to properly


authorize or govern oversight practices will not be effective without organizational buy-in
and accountability mechanisms, for example those suggested in the GOVERN function.

Suggested Actions
• Identify and document AI systems’ features and capabilities that require human
oversight, in relation to operational and societal contexts, trustworthy characteristics,
and risks identified in MAP-1.
• Establish practices for AI systems’ oversight in accordance with policies developed in
GOVERN-1.
• Define and develop training materials for relevant AI Actors about AI system
performance, context of use, known limitations and negative impacts, and suggested
warning labels.
• Include relevant AI Actors in AI system prototyping and testing activities. Conduct
testing activities under scenarios similar to deployment conditions.
• Evaluate AI system oversight practices for validity and reliability. When oversight
practices undergo extensive updates or adaptations, retest, evaluate results, and course
correct as necessary.

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• Verify that model documents contain interpretable descriptions of system mechanisms,
enabling oversight personnel to make informed, risk-based decisions about system
risks.

Transparency & Documentation

Organizations can document the following


• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• How does the entity assess whether personnel have the necessary skills, training,
resources, and domain knowledge to fulfill their assigned responsibilities?
• Are the relevant staff dealing with AI systems properly trained to interpret AI model
output and decisions as well as to detect and manage bias in data?
• To what extent has the entity documented the AI system’s development, testing
methodology, metrics, and performance outcomes?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.

References
Ben Green, “The Flaws of Policies Requiring Human Oversight of Government Algorithms,”
SSRN Journal, 2021.

Luciano Cavalcante Siebert, Maria Luce Lupetti, Evgeni Aizenberg, Niek Beckers, Arkady
Zgonnikov, Herman Veluwenkamp, David Abbink, Elisa Giaccardi, Geert-Jan Houben,
Catholijn Jonker, Jeroen van den Hoven, Deborah Forster, & Reginald Lagendijk (2021).
Meaningful human control: actionable properties for AI system development. AI and Ethics.

Mary Cummings, (2014). Automation and Accountability in Decision Support System


Interface Design. The Journal of Technology Studies. 32. 10.21061/jots.v32i1.a.4.

Madeleine Elish, M. (2016). Moral Crumple Zones: Cautionary Tales in Human-Robot


Interaction (WeRobot 2016). SSRN Electronic Journal. 10.2139/ssrn.2757236.

R Crootof, ME Kaminski, and WN Price II. Humans in the Loop (March 25, 2022). Vanderbilt
Law Review, Forthcoming 2023, U of Colorado Law Legal Studies Research Paper No. 22-10,
U of Michigan Public Law Research Paper No. 22-011.
[LINK](https://ssrn.com/abstract=4066781),

Bogdana Rakova, Jingying Yang, Henriette Cramer, & Rumman Chowdhury (2020). Where
Responsible AI meets Reality. Proceedings of the ACM on Human-Computer Interaction, 5, 1
- 23.

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MAP 4.1
Approaches for mapping AI technology and legal risks of its components – including the use
of third-party data or software – are in place, followed, and documented, as are risks of
infringement of a third-party’s intellectual property or other rights.

About
Technologies and personnel from third-parties are another potential sources of risk to
consider during AI risk management activities. Such risks may be difficult to map since risk
priorities or tolerances may not be the same as the deployer organization.

For example, the use of pre-trained models, which tend to rely on large uncurated dataset
or often have undisclosed origins, has raised concerns about privacy, bias, and
unanticipated effects along with possible introduction of increased levels of statistical
uncertainty, difficulty with reproducibility, and issues with scientific validity.

Suggested Actions
• Review audit reports, testing results, product roadmaps, warranties, terms of service,
end user license agreements, contracts, and other documentation related to third-party
entities to assist in value assessment and risk management activities.
• Review third-party software release schedules and software change management plans
(hotfixes, patches, updates, forward- and backward- compatibility guarantees) for
irregularities that may contribute to AI system risks.
• Inventory third-party material (hardware, open-source software, foundation models,
open source data, proprietary software, proprietary data, etc.) required for system
implementation and maintenance.
• Review redundancies related to third-party technology and personnel to assess
potential risks due to lack of adequate support.

Transparency & Documentation

Organizations can document the following


• Did you establish a process for third parties (e.g. suppliers, end users, subjects,
distributors/vendors or workers) to report potential vulnerabilities, risks or biases in
the AI system?
• If your organization obtained datasets from a third party, did your organization assess
and manage the risks of using such datasets?
• How will the results be independently verified?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• WEF Model AI Governance Framework Assessment 2020.

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References

Language models
Emily M. Bender, Timnit Gebru, Angelina McMillan-Major, and Shmargaret Shmitchell. 2021.
On the Dangers of Stochastic Parrots: Can Language Models Be Too Big? �. In Proceedings of
the 2021 ACM Conference on Fairness, Accountability, and Transparency (FAccT '21).
Association for Computing Machinery, New York, NY, USA, 610–623.

Julia Kreutzer, Isaac Caswell, Lisa Wang, et al. 2022. Quality at a Glance: An Audit of Web-
Crawled Multilingual Datasets. Transactions of the Association for Computational
Linguistics 10 (2022), 50–72.

Laura Weidinger, Jonathan Uesato, Maribeth Rauh, et al. 2022. Taxonomy of Risks posed by
Language Models. In 2022 ACM Conference on Fairness, Accountability, and Transparency
(FAccT '22). Association for Computing Machinery, New York, NY, USA, 214–229.

Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021.

Rishi Bommasani, Drew A. Hudson, Ehsan Adeli, et al. 2021. On the Opportunities and Risks
of Foundation Models. arXiv:2108.07258.

Jason Wei, Yi Tay, Rishi Bommasani, Colin Raffel, Barret Zoph, Sebastian Borgeaud, Dani
Yogatama, Maarten Bosma, Denny Zhou, Donald Metzler, Ed H. Chi, Tatsunori Hashimoto,
Oriol Vinyals, Percy Liang, Jeff Dean, William Fedus. “Emergent Abilities of Large Language
Models.” ArXiv abs/2206.07682 (2022).

MAP 4.2
Internal risk controls for components of the AI system including third-party AI technologies
are identified and documented.

About
In the course of their work, AI actors often utilize open-source, or otherwise freely
available, third-party technologies – some of which may have privacy, bias, and security
risks. Organizations may consider internal risk controls for these technology sources and
build up practices for evaluating third-party material prior to deployment.

Suggested Actions
• Track third-parties preventing or hampering risk-mapping as indications of increased
risk.
• Supply resources such as model documentation templates and software safelists to
assist in third-party technology inventory and approval activities.
• Review third-party material (including data and models) for risks related to bias, data
privacy, and security vulnerabilities.
• Apply traditional technology risk controls – such as procurement, security, and data
privacy controls – to all acquired third-party technologies.

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Transparency & Documentation

Organizations can document the following


• Can the AI system be audited by independent third parties?
• To what extent do these policies foster public trust and confidence in the use of the AI
system?
• Are mechanisms established to facilitate the AI system’s auditability (e.g. traceability of
the development process, the sourcing of training data and the logging of the AI
system’s processes, outcomes, positive and negative impact)?

AI Transparency Resources
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• WEF Model AI Governance Framework Assessment 2020.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI -
2019. [LINK](https://altai.insight-centre.org/),

References
Office of the Comptroller of the Currency. 2021. Comptroller's Handbook: Model Risk
Management, Version 1.0, August 2021. Retrieved on July 7, 2022.

Proposed Interagency Guidance on Third-Party Relationships: Risk Management, 2021.

Kang, D., Raghavan, D., Bailis, P.D., & Zaharia, M.A. (2020). Model Assertions for Monitoring
and Improving ML Models. ArXiv, abs/2003.01668.

MAP 5.1
Likelihood and magnitude of each identified impact (both potentially beneficial and
harmful) based on expected use, past uses of AI systems in similar contexts, public incident
reports, feedback from those external to the team that developed or deployed the AI system,
or other data are identified and documented.

About
AI actors can evaluate, document and triage the likelihood of AI system impacts identified in
Map 5.1 Likelihood estimates may then be assessed and judged for go/no-go decisions
about deploying an AI system. If an organization decides to proceed with deploying the
system, the likelihood and magnitude estimates can be used to assign TEVV resources
appropriate for the risk level.

Suggested Actions
• Establish assessment scales for measuring AI systems’ impact. Scales may be qualitative,
such as red-amber-green (RAG), or may entail simulations or econometric approaches.
Document and apply scales uniformly across the organization’s AI portfolio.
• Apply TEVV regularly at key stages in the AI lifecycle, connected to system impacts and
frequency of system updates.

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• Identify and document likelihood and magnitude of system benefits and negative
impacts in relation to trustworthiness characteristics.

Transparency & Documentation

Organizations can document the following


• Which population(s) does the AI system impact?
• What assessments has the entity conducted on trustworthiness characteristics for
example data security and privacy impacts associated with the AI system?
• Can the AI system be tested by independent third parties?

AI Transparency Resources
• Datasheets for Datasets.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI -
2019. [LINK](https://altai.insight-centre.org/),

References
Emilio Gómez-González and Emilia Gómez. 2020. Artificial intelligence in medicine and
healthcare. Joint Research Centre (European Commission).

Artificial Intelligence Incident Database. 2022.

Anthony M. Barrett, Dan Hendrycks, Jessica Newman and Brandie Nonnecke. “Actionable
Guidance for High-Consequence AI Risk Management: Towards Standards Addressing AI
Catastrophic Risks". ArXiv abs/2206.08966 (2022)

Ganguli, D., et al. (2022). Red Teaming Language Models to Reduce Harms: Methods, Scaling
Behaviors, and Lessons Learned. arXiv. https://arxiv.org/abs/2209.07858

MAP 5.2
Practices and personnel for supporting regular engagement with relevant AI actors and
integrating feedback about positive, negative, and unanticipated impacts are in place and
documented.

About
AI systems are socio-technical in nature and can have positive, neutral, or negative
implications that extend beyond their stated purpose. Negative impacts can be wide-
ranging and affect individuals, groups, communities, organizations, and society, as well as
the environment and national security.

Organizations can create a baseline for system monitoring to increase opportunities for
detecting emergent risks. After an AI system is deployed, engaging different stakeholder
groups – who may be aware of, or experience, benefits or negative impacts that are

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unknown to AI actors involved in the design, development and deployment activities –
allows organizations to understand and monitor system benefits and potential negative
impacts more readily.

Suggested Actions
• Establish and document stakeholder engagement processes at the earliest stages of
system formulation to identify potential impacts from the AI system on individuals,
groups, communities, organizations, and society.
• Employ methods such as value sensitive design (VSD) to identify misalignments
between organizational and societal values, and system implementation and impact.
• Identify approaches to engage, capture, and incorporate input from system end users
and other key stakeholders to assist with continuous monitoring for potential impacts
and emergent risks.
• Incorporate quantitative, qualitative, and mixed methods in the assessment and
documentation of potential impacts to individuals, groups, communities, organizations,
and society.
• Identify a team (internal or external) that is independent of AI design and development
functions to assess AI system benefits, positive and negative impacts and their
likelihood and magnitude.
• Evaluate and document stakeholder feedback to assess potential impacts for actionable
insights regarding trustworthiness characteristics and changes in design approaches
and principles.
• Develop TEVV procedures that incorporate socio-technical elements and methods and
plan to normalize across organizational culture. Regularly review and refine TEVV
processes.

Transparency & Documentation

Organizations can document the following


• If the AI system relates to people, does it unfairly advantage or disadvantage a
particular social group? In what ways? How was this managed?
• If the AI system relates to other ethically protected groups, have appropriate obligations
been met? (e.g., medical data might include information collected from animals)
• If the AI system relates to people, could this dataset expose people to harm or legal
action? (e.g., financial social or otherwise) What was done to mitigate or reduce the
potential for harm?

AI Transparency Resources
• Datasheets for Datasets.
• GAO-21-519SP: AI Accountability Framework for Federal Agencies & Other Entities.
• AI policies and initiatives, in Artificial Intelligence in Society, OECD, 2019.
• Intel.gov: AI Ethics Framework for Intelligence Community - 2020.
• Assessment List for Trustworthy AI (ALTAI) - The High-Level Expert Group on AI -
2019. [LINK](https://altai.insight-centre.org/),

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References
Susanne Vernim, Harald Bauer, Erwin Rauch, et al. 2022. A value sensitive design approach
for designing AI-based worker assistance systems in manufacturing. Procedia Comput. Sci.
200, C (2022), 505–516.

Harini Suresh and John V. Guttag. 2020. A Framework for Understanding Sources of Harm
throughout the Machine Learning Life Cycle. arXiv:1901.10002. Retrieved from

Margarita Boyarskaya, Alexandra Olteanu, and Kate Crawford. 2020. Overcoming Failures of
Imagination in AI Infused System Development and Deployment. arXiv:2011.13416.

Konstantinia Charitoudi and Andrew Blyth. A Socio-Technical Approach to Cyber Risk


Management and Impact Assessment. Journal of Information Security 4, 1 (2013), 33-41.

Raji, I.D., Smart, A., White, R.N., Mitchell, M., Gebru, T., Hutchinson, B., Smith-Loud, J., Theron,
D., & Barnes, P. (2020). Closing the AI accountability gap: defining an end-to-end framework
for internal algorithmic auditing. Proceedings of the 2020 Conference on Fairness,
Accountability, and Transparency.

Emanuel Moss, Elizabeth Anne Watkins, Ranjit Singh, Madeleine Clare Elish, & Jacob Metcalf.
2021. Assemlbing Accountability: Algorithmic Impact Assessment for the Public Interest.
Data & Society. Accessed 7/14/2022 at

Shari Trewin (2018). AI Fairness for People with Disabilities: Point of View. ArXiv,
abs/1811.10670.

Ada Lovelace Institute. 2022. Algorithmic Impact Assessment: A Case Study in Healthcare.
Accessed July 14, 2022.

Microsoft Responsible AI Impact Assessment Template. 2022. Accessed July 14, 2022.

Microsoft Responsible AI Impact Assessment Guide. 2022. Accessed July 14, 2022.

Microsoft Responsible AI Standard, v2.

Microsoft Research AI Fairness Checklist.

PEAT AI & Disability Inclusion Toolkit – Risks of Bias and Discrimination in AI Hiring Tools.

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MEASURE
Measure
Appropriate methods and metrics are identified and applied.

MEASURE 1.1
Approaches and metrics for measurement of AI risks enumerated during the Map function
are selected for implementation starting with the most significant AI risks. The risks or
trustworthiness characteristics that will not – or cannot – be measured are properly
documented.

About
The development and utility of trustworthy AI systems depends on reliable measurements
and evaluations of underlying technologies and their use. Compared with traditional
software systems, AI technologies bring new failure modes, inherent dependence on
training data and methods which directly tie to data quality and representativeness.
Additionally, AI systems are inherently socio-technical in nature, meaning they are
influenced by societal dynamics and human behavior. AI risks – and benefits – can emerge
from the interplay of technical aspects combined with societal factors related to how a
system is used, its interactions with other AI systems, who operates it, and the social
context in which it is deployed. In other words, What should be measured depends on the
purpose, audience, and needs of the evaluations.

These two factors influence selection of approaches and metrics for measurement of AI
risks enumerated during the Map function. The AI landscape is evolving and so are the
methods and metrics for AI measurement. The evolution of metrics is key to maintaining
efficacy of the measures.

Suggested Actions
• Establish approaches for detecting, tracking and measuring known risks, errors,
incidents or negative impacts.
• Identify testing procedures and metrics to demonstrate whether or not the system is fit
for purpose and functioning as claimed.
• Identify testing procedures and metrics to demonstrate AI system trustworthiness
• Define acceptable limits for system performance (e.g. distribution of errors), and
include course correction suggestions if/when the system performs beyond acceptable
limits.
• Define metrics for, and regularly assess, AI actor competency for effective system
operation,
• Identify transparency metrics to assess whether stakeholders have access to necessary
information about system design, development, deployment, use, and evaluation.
• Utilize accountability metrics to determine whether AI designers, developers, and
deployers maintain clear and transparent lines of responsibility and are open to
inquiries.
• Document metric selection criteria and include considered but unused metrics.

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• Monitor AI system external inputs including training data, models developed for other
contexts, system components reused from other contexts, and third-party tools and
resources.
• Report metrics to inform assessments of system generalizability and reliability.
• Assess and document pre- vs post-deployment system performance. Include existing
and emergent risks.
• Document risks or trustworthiness characteristics identified in the Map function that
will not be measured, including justification for non- measurement.

Transparency & Documentation

Organizations can document the following


• How will the appropriate performance metrics, such as accuracy, of the AI be monitored
after the AI is deployed?
• What corrective actions has the entity taken to enhance the quality, accuracy, reliability,
and representativeness of the data?
• Are there recommended data splits or evaluation measures? (e.g., training,
development, testing; accuracy/AUC)
• Did your organization address usability problems and test whether user interfaces
served their intended purposes?
• What testing, if any, has the entity conducted on the AI system to identify errors and
limitations (i.e. manual vs automated, adversarial and stress testing)?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• Datasheets for Datasets.

References
Sara R. Jordan. “Designing Artificial Intelligence Review Boards: Creating Risk Metrics for
Review of AI.” 2019 IEEE International Symposium on Technology and Society (ISTAS),
2019.

IEEE. “IEEE-1012-2016: IEEE Standard for System, Software, and Hardware Verification and
Validation.” IEEE Standards Association.

ACM Technology Policy Council. “Statement on Principles for Responsible Algorithmic


Systems.” Association for Computing Machinery (ACM), October 26, 2022.

Perez, E., et al. (2022). Discovering Language Model Behaviors with Model-Written
Evaluations. arXiv. https://arxiv.org/abs/2212.09251

Ganguli, D., et al. (2022). Red Teaming Language Models to Reduce Harms: Methods, Scaling
Behaviors, and Lessons Learned. arXiv. https://arxiv.org/abs/2209.07858

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David Piorkowski, Michael Hind, and John Richards. "Quantitative AI Risk Assessments:
Opportunities and Challenges." arXiv preprint, submitted January 11, 2023.

Daniel Schiff, Aladdin Ayesh, Laura Musikanski, and John C. Havens. “IEEE 7010: A New
Standard for Assessing the Well-Being Implications of Artificial Intelligence.” 2020 IEEE
International Conference on Systems, Man, and Cybernetics (SMC), 2020.

MEASURE 1.2
Appropriateness of AI metrics and effectiveness of existing controls is regularly assessed
and updated including reports of errors and impacts on affected communities.

About
Different AI tasks, such as neural networks or natural language processing, benefit from
different evaluation techniques. Use-case and particular settings in which the AI system is
used also affects appropriateness of the evaluation techniques. Changes in the operational
settings, data drift, model drift are among factors that suggest regularly assessing and
updating appropriateness of AI metrics and their effectiveness can enhance reliability of AI
system measurements.

Suggested Actions
• Assess external validity of all measurements (e.g., the degree to which measurements
taken in one context can generalize to other contexts).
• Assess effectiveness of existing metrics and controls on a regular basis throughout the
AI system lifecycle.
• Document reports of errors, incidents and negative impacts and assess sufficiency and
efficacy of existing metrics for repairs, and upgrades
• Develop new metrics when existing metrics are insufficient or ineffective for
implementing repairs and upgrades.
• Develop and utilize metrics to monitor, characterize and track external inputs, including
any third-party tools.
• Determine frequency and scope for sharing metrics and related information with
stakeholders and impacted communities.
• Utilize stakeholder feedback processes established in the Map function to capture, act
upon and share feedback from end users and potentially impacted communities.
• Collect and report software quality metrics such as rates of bug occurrence and severity,
time to response, and time to repair (See Manage 4.3).

Transparency & Documentation

Organizations can document the following


• What metrics has the entity developed to measure performance of the AI system?
• To what extent do the metrics provide accurate and useful measure of performance?
• What corrective actions has the entity taken to enhance the quality, accuracy, reliability,
and representativeness of the data?

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• How will the accuracy or appropriate performance metrics be assessed?
• What is the justification for the metrics selected?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
ACM Technology Policy Council. “Statement on Principles for Responsible Algorithmic
Systems.” Association for Computing Machinery (ACM), October 26, 2022.

Trevor Hastie, Robert Tibshirani, and Jerome Friedman. The Elements of Statistical
Learning: Data Mining, Inference, and Prediction. 2nd ed. Springer-Verlag, 2009.

Harini Suresh and John Guttag. “A Framework for Understanding Sources of Harm
Throughout the Machine Learning Life Cycle.” Equity and Access in Algorithms,
Mechanisms, and Optimization, October 2021.

Christopher M. Bishop. Pattern Recognition and Machine Learning. New York: Springer,
2006.

Solon Barocas, Anhong Guo, Ece Kamar, Jacquelyn Krones, Meredith Ringel Morris, Jennifer
Wortman Vaughan, W. Duncan Wadsworth, and Hanna Wallach. “Designing Disaggregated
Evaluations of AI Systems: Choices, Considerations, and Tradeoffs.” Proceedings of the 2021
AAAI/ACM Conference on AI, Ethics, and Society, July 2021, 368–78.

MEASURE 1.3
Internal experts who did not serve as front-line developers for the system and/or
independent assessors are involved in regular assessments and updates. Domain experts,
users, AI actors external to the team that developed or deployed the AI system, and affected
communities are consulted in support of assessments as necessary per organizational risk
tolerance.

About
The current AI systems are brittle, the failure modes are not well described, and the systems
are dependent on the context in which they were developed and do not transfer well
outside of the training environment. A reliance on local evaluations will be necessary along
with a continuous monitoring of these systems. Measurements that extend beyond classical
measures (which average across test cases) or expand to focus on pockets of failures where
there are potentially significant costs can improve the reliability of risk management
activities. Feedback from affected communities about how AI systems are being used can
make AI evaluation purposeful. Involving internal experts who did not serve as front-line
developers for the system and/or independent assessors regular assessments of AI systems
helps a fulsome characterization of AI systems’ performance and trustworthiness .

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Suggested Actions
• Evaluate TEVV processes regarding incentives to identify risks and impacts.
• Utilize separate testing teams established in the Govern function (2.1 and 4.1) to enable
independent decisions and course-correction for AI systems. Track processes and
measure and document change in performance.
• Plan and evaluate AI system prototypes with end user populations early and
continuously in the AI lifecycle. Document test outcomes and course correct.
• Assess independence and stature of TEVV and oversight AI actors, to ensure they have
the required levels of independence and resources to perform assurance, compliance,
and feedback tasks effectively
• Evaluate interdisciplinary and demographically diverse internal team established in
Map 1.2
• Evaluate effectiveness of external stakeholder feedback mechanisms, specifically related
to processes for eliciting, evaluating and integrating input from diverse groups.
• Evaluate effectiveness of external stakeholder feedback mechanisms for enhancing AI
actor visibility and decision making regarding AI system risks and trustworthy
characteristics.
• Identify and utilize participatory approaches for assessing impacts that may arise from
changes in system deployment (e.g., introducing new technology, decommissioning
algorithms and models, adapting system, model or algorithm)

Transparency & Documentation

Organizations can document the following


• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?
• How easily accessible and current is the information available to external stakeholders?
• To what extent does the entity communicate its AI strategic goals and objectives to the
community of stakeholders?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• To what extent is this information sufficient and appropriate to promote transparency?
Do external stakeholders have access to information on the design, operation, and
limitations of the AI system?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

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References
Board of Governors of the Federal Reserve System. “SR 11-7: Guidance on Model Risk
Management.” April 4, 2011.

“Definition of independent verification and validation (IV&V)”, in IEEE 1012, IEEE Standard
for System, Software, and Hardware Verification and Validation. Annex C,

Mona Sloane, Emanuel Moss, Olaitan Awomolo, and Laura Forlano. “Participation Is Not a
Design Fix for Machine Learning.” Equity and Access in Algorithms, Mechanisms, and
Optimization, October 2022.

Rediet Abebe and Kira Goldner. “Mechanism Design for Social Good.” AI Matters 4, no. 3
(October 2018): 27–34.

Upol Ehsan, Ranjit Singh, Jacob Metcalf and Mark O. Riedl. “The Algorithmic Imprint.”
Proceedings of the 2022 ACM Conference on Fairness, Accountability, and Transparency
(2022).

MEASURE 2.1
Test sets, metrics, and details about the tools used during test, evaluation, validation, and
verification (TEVV) are documented.

About
Documenting measurement approaches, test sets, metrics, processes and materials used,
and associated details builds foundation upon which to build a valid, reliable measurement
process. Documentation enables repeatability and consistency, and can enhance AI risk
management decisions.

Suggested Actions
• Leverage existing industry best practices for transparency and documentation of all
possible aspects of measurements. Examples include: data sheet for data sets, model
cards
• Regularly assess the effectiveness of tools used to document measurement approaches,
test sets, metrics, processes and materials used
• Update the tools as needed

Transparency & Documentation

Organizations can document the following


• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• To what extent has the entity documented the AI system’s development, testing
methodology, metrics, and performance outcomes?

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AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020.

References
Emily M. Bender and Batya Friedman. “Data Statements for Natural Language Processing:
Toward Mitigating System Bias and Enabling Better Science.” Transactions of the
Association for Computational Linguistics 6 (2018): 587–604.

Margaret Mitchell, Simone Wu, Andrew Zaldivar, Parker Barnes, Lucy Vasserman, Ben
Hutchinson, Elena Spitzer, Inioluwa Deborah Raji, and Timnit Gebru. “Model Cards for
Model Reporting.” FAT *19: Proceedings of the Conference on Fairness, Accountability, and
Transparency, January 2019, 220–29.

IEEE Computer Society. “Software Engineering Body of Knowledge Version 3: IEEE


Computer Society.” IEEE Computer Society.

IEEE. “IEEE-1012-2016: IEEE Standard for System, Software, and Hardware Verification and
Validation.” IEEE Standards Association.

Board of Governors of the Federal Reserve System. “SR 11-7: Guidance on Model Risk
Management.” April 4, 2011.

Abigail Z. Jacobs and Hanna Wallach. “Measurement and Fairness.” FAccT '21: Proceedings
of the 2021 ACM Conference on Fairness, Accountability, and Transparency, March 2021,
375–85.

Jeanna Matthews, Bruce Hedin, Marc Canellas. Trustworthy Evidence for Trustworthy
Technology: An Overview of Evidence for Assessing the Trustworthiness of Autonomous
and Intelligent Systems. IEEE-USA, September 29 2022.

Roel Dobbe, Thomas Krendl Gilbert, and Yonatan Mintz. “Hard Choices in Artificial
Intelligence.” Artificial Intelligence 300 (November 2021).

MEASURE 2.2
Evaluations involving human subjects meet applicable requirements (including human
subject protection) and are representative of the relevant population.

About
Measurement and evaluation of AI systems often involves testing with human subjects or
using data captured from human subjects. Protection of human subjects is required by law
when carrying out federally funded research, and is a domain specific requirement for some
disciplines. Standard human subjects protection procedures include protecting the welfare

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and interests of human subjects, designing evaluations to minimize risks to subjects, and
completion of mandatory training regarding legal requirements and expectations.

Evaluations of AI system performance that utilize human subjects or human subject data
should reflect the population within the context of use. AI system activities utilizing non-
representative data may lead to inaccurate assessments or negative and harmful outcomes.
It is often difficult – and sometimes impossible, to collect data or perform evaluation tasks
that reflect the full operational purview of an AI system. Methods for collecting, annotating,
or using these data can also contribute to the challenge. To counteract these challenges,
organizations can connect human subjects data collection, and dataset practices, to AI
system contexts and purposes and do so in close collaboration with AI Actors from the
relevant domains.

Suggested Actions
• Follow human subjects research requirements as established by organizational and
disciplinary requirements, including informed consent and compensation, during
dataset collection activities.
• Analyze differences between intended and actual population of users or data subjects,
including likelihood for errors, incidents or negative impacts.
• Utilize disaggregated evaluation methods (e.g. by race, age, gender, ethnicity, ability,
region) to improve AI system performance when deployed in real world settings.
• Establish thresholds and alert procedures for dataset representativeness within the
context of use.
• Construct datasets in close collaboration with experts with knowledge of the context of
use.
• Follow intellectual property and privacy rights related to datasets and their use,
including for the subjects represented in the data.
• Evaluate data representativeness through
• Use informed consent for individuals providing data used in system testing and
evaluation.

Transparency & Documentation

Organizations can document the following


• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• How has the entity identified and mitigated potential impacts of bias in the data,
including inequitable or discriminatory outcomes?
• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?
• To what extent has the entity identified and mitigated potential bias—statistical,
contextual, and historical—in the data?
• If it relates to people, were they told what the dataset would be used for and did they
consent? What community norms exist for data collected from human communications?

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If consent was obtained, how? Were the people provided with any mechanism to revoke
their consent in the future or for certain uses?
• If human subjects were used in the development or testing of the AI system, what
protections were put in place to promote their safety and wellbeing?.

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020.
• Datasheets for Datasets.

References
United States Department of Health, Education, and Welfare's National Commission for the
Protection of Human Subjects of Biomedical and Behavioral Research. The Belmont Report:
Ethical Principles and Guidelines for the Protection of Human Subjects of Research. Volume
II. United States Department of Health and Human Services Office for Human Research
Protections. April 18, 1979.

Office for Human Research Protections (OHRP). “45 CFR 46.” United States Department of
Health and Human Services Office for Human Research Protections, March 10, 2021.

Office for Human Research Protections (OHRP). “Human Subject Regulations Decision
Chart.” United States Department of Health and Human Services Office for Human Research
Protections, June 30, 2020.

Jacob Metcalf and Kate Crawford. “Where Are Human Subjects in Big Data Research? The
Emerging Ethics Divide.” Big Data and Society 3, no. 1 (2016).

Boaz Shmueli, Jan Fell, Soumya Ray, and Lun-Wei Ku. "Beyond Fair Pay: Ethical Implications
of NLP Crowdsourcing." arXiv preprint, submitted April 20, 2021.

Divyansh Kaushik, Zachary C. Lipton, and Alex John London. "Resolving the Human Subjects
Status of Machine Learning's Crowdworkers." arXiv preprint, submitted June 8, 2022.

Office for Human Research Protections (OHRP). “International Compilation of Human


Research Standards.” United States Department of Health and Human Services Office for
Human Research Protections, February 7, 2022.

National Institutes of Health. “Definition of Human Subjects Research.” NIH Central


Resource for Grants and Funding Information, January 13, 2020.

Joy Buolamwini and Timnit Gebru. “Gender Shades: Intersectional Accuracy Disparities in
Commercial Gender Classification.” Proceedings of the 1st Conference on Fairness,
Accountability and Transparency in PMLR 81 (2018): 77–91.

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Eun Seo Jo and Timnit Gebru. “Lessons from Archives: Strategies for Collecting Sociocultural
Data in Machine Learning.” FAT* '20: Proceedings of the 2020 Conference on Fairness,
Accountability, and Transparency, January 2020, 306–16.

Marco Gerardi, Katarzyna Barud, Marie-Catherine Wagner, Nikolaus Forgo, Francesca


Fallucchi, Noemi Scarpato, Fiorella Guadagni, and Fabio Massimo Zanzotto. "Active
Informed Consent to Boost the Application of Machine Learning in Medicine." arXiv
preprint, submitted September 27, 2022.

Shari Trewin. "AI Fairness for People with Disabilities: Point of View." arXiv preprint,
submitted November 26, 2018.

Andrea Brennen, Ryan Ashley, Ricardo Calix, JJ Ben-Joseph, George Sieniawski, Mona Gogia,
and BNH.AI. AI Assurance Audit of RoBERTa, an Open source, Pretrained Large Language
Model. IQT Labs, December 2022.

MEASURE 2.3
AI system performance or assurance criteria are measured qualitatively or quantitatively
and demonstrated for conditions similar to deployment setting(s). Measures are
documented.

About
The current risk and impact environment suggests AI system performance estimates are
insufficient and require a deeper understanding of deployment context of use.
Computationally focused performance testing and evaluation schemes are restricted to test
data sets and in silico techniques. These approaches do not directly evaluate risks and
impacts in real world environments and can only predict what might create impact based
on an approximation of expected AI use. To properly manage risks, more direct information
is necessary to understand how and under what conditions deployed AI creates impacts,
who is most likely to be impacted, and what that experience is like.

Suggested Actions
• Conduct regular and sustained engagement with potentially impacted communities
• Maintain a demographically diverse and multidisciplinary and collaborative internal
team
• Regularly test and evaluate systems in non-optimized conditions, and in collaboration
with AI actors in user interaction and user experience (UI/UX) roles.
• Evaluate feedback from stakeholder engagement activities, in collaboration with human
factors and socio-technical experts.
• Collaborate with socio-technical, human factors, and UI/UX experts to identify notable
characteristics in context of use that can be translated into system testing scenarios.
• Measure AI systems prior to deployment in conditions similar to expected scenarios.
• Measure and document performance criteria such as validity (false positive rate, false
negative rate, etc.) and efficiency (training times, prediction latency, etc.) related to
ground truth within the deployment context of use.

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• Measure assurance criteria such as AI actor competency and experience.
• Document differences between measurement setting and the deployment
environment(s).

Transparency & Documentation

Organizations can document the following


• What experiments were initially run on this dataset? To what extent have experiments
on the AI system been documented?
• To what extent does the system/entity consistently measure progress towards stated
goals and objectives?
• How will the appropriate performance metrics, such as accuracy, of the AI be monitored
after the AI is deployed? How much distributional shift or model drift from baseline
performance is acceptable?
• As time passes and conditions change, is the training data still representative of the
operational environment?
• What testing, if any, has the entity conducted on theAI system to identify errors and
limitations (i.e.adversarial or stress testing)?

AI Transparency Resources
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020.
• Datasheets for Datasets.

References
Trevor Hastie, Robert Tibshirani, and Jerome Friedman. The Elements of Statistical
Learning: Data Mining, Inference, and Prediction. 2nd ed. Springer-Verlag, 2009.

Jessica Zosa Forde, A. Feder Cooper, Kweku Kwegyir-Aggrey, Chris De Sa, and Michael
Littman. "Model Selection's Disparate Impact in Real-World Deep Learning Applications."
arXiv preprint, submitted September 7, 2021.

Inioluwa Deborah Raji, I. Elizabeth Kumar, Aaron Horowitz, and Andrew Selbst. “The Fallacy
of AI Functionality.” FAccT '22: 2022 ACM Conference on Fairness, Accountability, and
Transparency, June 2022, 959–72.

Amandalynne Paullada, Inioluwa Deborah Raji, Emily M. Bender, Emily Denton, and Alex
Hanna. “Data and Its (Dis)Contents: A Survey of Dataset Development and Use in Machine
Learning Research.” Patterns 2, no. 11 (2021): 100336.

Christopher M. Bishop. Pattern Recognition and Machine Learning. New York: Springer,
2006.

Md Johirul Islam, Giang Nguyen, Rangeet Pan, and Hridesh Rajan. "A Comprehensive Study
on Deep Learning Bug Characteristics." arXiv preprint, submitted June 3, 2019.

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Swaroop Mishra, Anjana Arunkumar, Bhavdeep Sachdeva, Chris Bryan, and Chitta Baral.
"DQI: Measuring Data Quality in NLP." arXiv preprint, submitted May 2, 2020.

Doug Wielenga. "Paper 073-2007: Identifying and Overcoming Common Data Mining
Mistakes." SAS Global Forum 2007: Data Mining and Predictive Modeling, SAS Institute,
2007.

Software Resources
• Drifter library (performance assessment)
• Manifold library (performance assessment)
• MLextend library (performance assessment)
• PiML library (explainable models, performance assessment)
• SALib library (performance assessment)
• What-If Tool (performance assessment)

MEASURE 2.4
The functionality and behavior of the AI system and its components – as identified in the
MAP function – are monitored when in production.

About
AI systems may encounter new issues and risks while in production as the environment
evolves over time. This effect, often referred to as “drift”, means AI systems no longer meet
the assumptions and limitations of the original design. Regular monitoring allows AI Actors
to monitor the functionality and behavior of the AI system and its components – as
identified in the MAP function - and enhance the speed and efficacy of necessary system
interventions.

Suggested Actions
• Monitor and document how metrics and performance indicators observed in production
differ from the same metrics collected during pre-deployment testing. When differences
are observed, consider error propagation and feedback loop risks.
• Utilize hypothesis testing or human domain expertise to measure monitored
distribution differences in new input or output data relative to test environments
• Monitor for anomalies using approaches such as control limits, confidence intervals,
integrity constraints and ML algorithms. When anomalies are observed, consider error
propagation and feedback loop risks.
• Verify alerts are in place for when distributions in new input data or generated
predictions observed in production differ from pre-deployment test outcomes, or when
anomalies are detected.
• Assess the accuracy and quality of generated outputs against new collected ground-
truth information as it becomes available.
• Utilize human review to track processing of unexpected data and reliability of generated
outputs; warn system users when outputs may be unreliable. Verify that human

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overseers responsible for these processes have clearly defined responsibilities and
training for specified tasks.
• Collect uses cases from the operational environment for system testing and monitoring
activities in accordance with organizational policies and regulatory or disciplinary
requirements (e.g. informed consent, institutional review board approval, human
research protections),

Transparency & Documentation

Organizations can document the following


• To what extent is the output of each component appropriate for the operational
context?
• What justifications, if any, has the entity provided for the assumptions, boundaries, and
limitations of the AI system?
• How will the appropriate performance metrics, such as accuracy, of the AI be monitored
after the AI is deployed?
• As time passes and conditions change, is the training data still representative of the
operational environment?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Luca Piano, Fabio Garcea, Valentina Gatteschi, Fabrizio Lamberti, and Lia Morra. “Detecting
Drift in Deep Learning: A Methodology Primer.” IT Professional 24, no. 5 (2022): 53–60.

Larysa Visengeriyeva, et al. “Awesome MLOps.“ GitHub.

MEASURE 2.5
The AI system to be deployed is demonstrated to be valid and reliable. Limitations of the
generalizability beyond the conditions under which the technology was developed are
documented.

About
An AI system that is not validated or that fails validation may be inaccurate or unreliable or
may generalize poorly to data and settings beyond its training, creating and increasing AI
risks and reducing trustworthiness. AI Actors can improve system validity by creating
processes for exploring and documenting system limitations. This includes broad
consideration of purposes and uses for which the system was not designed.

Validation risks include the use of proxies or other indicators that are often constructed by
AI development teams to operationalize phenomena that are either not directly observable
or measurable (e.g, fairness, hireability, honesty, propensity to commit a crime). Teams can

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mitigate these risks by demonstrating that the indicator is measuring the concept it claims
to measure (also known as construct validity). Without this and other types of validation,
various negative properties or impacts may go undetected, including the presence of
confounding variables, potential spurious correlations, or error propagation and its
potential impact on other interconnected systems.

Suggested Actions
• Define the operating conditions and socio-technical context under which the AI system
will be validated.
• Define and document processes to establish the system’s operational conditions and
limits.
• Establish or identify, and document approaches to measure forms of validity, including:
• Assess and document system variance. Standard approaches include confidence
intervals, standard deviation, standard error, bootstrapping, or cross-validation.
• Establish or identify, and document robustness measures.
• Establish or identify, and document reliability measures.
• Establish practices to specify and document the assumptions underlying measurement
models to ensure proxies accurately reflect the concept being measured.
• Utilize standard software testing approaches (e.g. unit, integration, functional and chaos
testing, computer-generated test cases, etc.)
• Utilize standard statistical methods to test bias, inferential associations, correlation, and
covariance in adopted measurement models.
• Utilize standard statistical methods to test variance and reliability of system outcomes.
• Monitor operating conditions for system performance outside of defined limits.
• Identify TEVV approaches for exploring AI system limitations, including testing
scenarios that differ from the operational environment. Consult experts with knowledge
of specific context of use.
• Define post-alert actions. Possible actions may include:
• Log input data and relevant system configuration information whenever there is an
attempt to use the system beyond its well-defined range of system validity.
• Modify the system over time to extend its range of system validity to new operating
conditions.

Transparency & Documentation

Organizations can document the following


• What testing, if any, has the entity conducted on theAI system to identify errors and
limitations (i.e.adversarial or stress testing)?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• How has the entity identified and mitigated potential impacts of bias in the data,
including inequitable or discriminatory outcomes?

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• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?
• What goals and objectives does the entity expect to achieve by designing, developing,
and/or deploying the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

References
Abigail Z. Jacobs and Hanna Wallach. “Measurement and Fairness.” FAccT '21: Proceedings
of the 2021 ACM Conference on Fairness, Accountability, and Transparency, March 2021,
375–85.

Debugging Machine Learning Models. Proceedings of ICLR 2019 Workshop, May 6, 2019,
New Orleans, Louisiana.

Patrick Hall. “Strategies for Model Debugging.” Towards Data Science, November 8, 2019.

Suchi Saria and Adarsh Subbaswamy. "Tutorial: Safe and Reliable Machine Learning." arXiv
preprint, submitted April 15, 2019.

Google Developers. “Overview of Debugging ML Models.” Google Developers Machine


Learning Foundational Courses, n.d.

R. Mohanani, I. Salman, B. Turhan, P. Rodríguez and P. Ralph, "Cognitive Biases in Software


Engineering: A Systematic Mapping Study," in IEEE Transactions on Software Engineering,
vol. 46, no. 12, pp. 1318-1339, Dec. 2020,

Software Resources
• Drifter library (performance assessment)
• Manifold library (performance assessment)
• MLextend library (performance assessment)
• PiML library (explainable models, performance assessment)
• SALib library (performance assessment)
• What-If Tool (performance assessment)

MEASURE 2.6
AI system is evaluated regularly for safety risks – as identified in the MAP function. The AI
system to be deployed is demonstrated to be safe, its residual negative risk does not exceed
the risk tolerance, and can fail safely, particularly if made to operate beyond its knowledge
limits. Safety metrics implicate system reliability and robustness, real-time monitoring, and
response times for AI system failures.

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About
Many AI systems are being introduced into settings such as transportation, manufacturing
or security, where failures may give rise to various physical or environmental harms. AI
systems that may endanger human life, health, property or the environment are tested
thoroughly prior to deployment, and are regularly evaluated to confirm the system is safe
during normal operations, and in settings beyond its proposed use and knowledge limits.

Measuring activities for safety often relate to exhaustive testing in development and
deployment contexts, understanding the limits of a system’s reliable, robust, and safe
behavior, and real-time monitoring of various aspects of system performance. These
activities are typically conducted along with other risk mapping, management, and
governance tasks such as avoiding past failed designs, establishing and rehearsing incident
response plans that enable quick responses to system problems, the instantiation of
redundant functionality to cover failures, and transparent and accountable governance.
System safety incidents or failures are frequently reported to be related to organizational
dynamics and culture. Independent auditors may bring important independent perspectives
for reviewing evidence of AI system safety.

Suggested Actions
• Thoroughly measure system performance in development and deployment contexts,
and under stress conditions.
• Measure and monitor system performance in real-time to enable rapid response when
AI system incidents are detected.
• Collect pertinent safety statistics (e.g., out-of-range performance, incident response
times, system down time, injuries, etc.) in anticipation of potential information sharing
with impacted communities or as required by AI system oversight personnel.
• Align measurement to the goal of continuous improvement. Seek to increase the range
of conditions under which the system is able to fail safely through system modifications
in response to in-production testing and events.
• Document, practice and measure incident response plans for AI system incidents,
including measuring response and down times.
• Compare documented safety testing and monitoring information with established risk
tolerances on an on-going basis.
• Consult MANAGE for detailed information related to managing safety risks.

Transparency & Documentation

Organizations can document the following


• What testing, if any, has the entity conducted on the AI system to identify errors and
limitations (i.e.adversarial or stress testing)?
• To what extent has the entity documented the AI system’s development, testing
methodology, metrics, and performance outcomes?

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• Did you establish mechanisms that facilitate the AI system’s auditability (e.g.
traceability of the development process, the sourcing of training data and the logging of
the AI system’s processes, outcomes, positive and negative impact)?
• Did you ensure that the AI system can be audited by independent third parties?
• Did you establish a process for third parties (e.g. suppliers, end-users, subjects,
distributors/vendors or workers) to report potential vulnerabilities, risks or biases in
the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
AI Incident Database. 2022.

AIAAIC Repository. 2022.

Netflix. Chaos Monkey.

IBM. “IBM's Principles of Chaos Engineering.” IBM, n.d.

Suchi Saria and Adarsh Subbaswamy. "Tutorial: Safe and Reliable Machine Learning." arXiv
preprint, submitted April 15, 2019.

Daniel Kang, Deepti Raghavan, Peter Bailis, and Matei Zaharia. "Model assertions for
monitoring and improving ML models." Proceedings of Machine Learning and Systems 2
(2020): 481-496.

Larysa Visengeriyeva, et al. “Awesome MLOps.“ GitHub.

McGregor, S., Paeth, K., & Lam, K.T. (2022). Indexing AI Risks with Incidents, Issues, and
Variants. ArXiv, abs/2211.10384.

MEASURE 2.7
AI system security and resilience – as identified in the MAP function – are evaluated and
documented.

About
AI systems, as well as the ecosystems in which they are deployed, may be said to be resilient
if they can withstand unexpected adverse events or unexpected changes in their
environment or use – or if they can maintain their functions and structure in the face of
internal

and external change and degrade safely and gracefully when this is necessary. Common
security concerns relate to adversarial examples, data poisoning, and the exfiltration of
models, training data, or other intellectual property through AI system endpoints. AI

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systems that can maintain confidentiality, integrity, and availability through protection
mechanisms that prevent unauthorized access and use may be said to be secure.

Security and resilience are related but distinct characteristics. While resilience is the ability

to return to normal function after an unexpected adverse event, security includes resilience

but also encompasses protocols to avoid, protect against, respond to, or recover

from attacks. Resilience relates to robustness and encompasses unexpected or adversarial


use (or abuse or misuse) of the model or data.

Suggested Actions
• Establish and track AI system security tests and metrics (e.g., red-teaming activities,
frequency and rate of anomalous events, system down-time, incident response times,
time-to-bypass, etc.).
• Use red-team exercises to actively test the system under adversarial or stress
conditions, measure system response, assess failure modes or determine if system can
return to normal function after an unexpected adverse event.
• Document red-team exercise results as part of continuous improvement efforts,
including the range of security test conditions and results.
• Use countermeasures (e.g, authentication, throttling, differential privacy, robust ML
approaches) to increase the range of security conditions under which the system is able
to return to normal function.
• Modify system security procedures and countermeasures to increase robustness and
resilience to attacks in response to testing and events experienced in production.
• Verify that information about errors and attack patterns is shared with incident
databases, other organizations with similar systems, and system users and stakeholders
(MANAGE-4.1).
• Develop and maintain information sharing practices with AI actors from other
organizations to learn from common attacks.
• Verify that third party AI resources and personnel undergo security audits and
screenings. Risk indicators may include failure of third parties to provide relevant
security information.
• Utilize watermarking technologies as a deterrent to data and model extraction attacks.

Transparency & Documentation

Organizations can document the following


• To what extent does the plan specifically address risks associated with acquisition,
procurement of packaged software from vendors, cybersecurity controls, computational
infrastructure, data, data science, deployment mechanics, and system failure?
• What assessments has the entity conducted on data security and privacy impacts
associated with the AI system?

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• What processes exist for data generation, acquisition/collection, security, maintenance,
and dissemination?
• What testing, if any, has the entity conducted on the AI system to identify errors and
limitations (i.e. adversarial or stress testing)?
• If a third party created the AI, how will you ensure a level of explainability or
interpretability?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Matthew P. Barrett. “Framework for Improving Critical Infrastructure Cybersecurity
Version 1.1.” National Institute of Standards and Technology (NIST), April 16, 2018.

Nicolas Papernot. "A Marauder's Map of Security and Privacy in Machine Learning." arXiv
preprint, submitted on November 3, 2018.

Gary McGraw, Harold Figueroa, Victor Shepardson, and Richie Bonett. “BIML Interactive
Machine Learning Risk Framework.” Berryville Institute of Machine Learning (BIML), 2022.

Mitre Corporation. “Mitre/Advmlthreatmatrix: Adversarial Threat Landscape for AI


Systems.” GitHub, 2023.

National Institute of Standards and Technology (NIST). “Cybersecurity Framework.” NIST,


2023.

Software Resources
• adversarial-robustness-toolbox
• counterfit
• foolbox
• ml_privacy_meter
• robustness
• tensorflow/privacy

MEASURE 2.8
Risks associated with transparency and accountability – as identified in the MAP function –
are examined and documented.

About
Transparency enables meaningful visibility into entire AI pipelines, workflows, processes or
organizations and decreases information asymmetry between AI developers and operators
and other AI Actors and impacted communities. Transparency is a central element of
effective AI risk management that enables insight into how an AI system is working, and the

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ability to address risks if and when they emerge. The ability for system users, individuals, or
impacted communities to seek redress for incorrect or problematic AI system outcomes is
one control for transparency and accountability. Higher level recourse processes are
typically enabled by lower level implementation efforts directed at explainability and
interpretability functionality. See Measure 2.9.

Transparency and accountability across organizations and processes is crucial to reducing


AI risks. Accountable leadership – whether individuals or groups – and transparent roles,
responsibilities, and lines of communication foster and incentivize quality assurance and
risk management activities within organizations.

Lack of transparency complicates measurement of trustworthiness and whether AI systems


or organizations are subject to effects of various individual and group biases and design
blindspots and could lead to diminished user, organizational and community trust, and
decreased overall system value. Enstating accountable and transparent organizational
structures along with documenting system risks can enable system improvement and risk
management efforts, allowing AI actors along the lifecycle to identify errors, suggest
improvements, and figure out new ways to contextualize and generalize AI system features
and outcomes.

Suggested Actions
• Instrument the system for measurement and tracking, e.g., by maintaining histories,
audit logs and other information that can be used by AI actors to review and evaluate
possible sources of error, bias, or vulnerability.
• Calibrate controls for users in close collaboration with experts in user interaction and
user experience (UI/UX), human computer interaction (HCI), and/or human-AI teaming.
• Test provided explanations for calibration with different audiences including operators,
end users, decision makers and decision subjects (individuals for whom decisions are
being made), and to enable recourse for consequential system decisions that affect end
users or subjects.
• Measure and document human oversight of AI systems:
• Track, document, and measure organizational accountability regarding AI systems via
policy exceptions and escalations, and document “go” and “no/go” decisions made by
accountable parties.
• Track and audit the effectiveness of organizational mechanisms related to AI risk
management, including:

Transparency & Documentation

Organizations can document the following


• To what extent has the entity clarified the roles, responsibilities, and delegated
authorities to relevant stakeholders?
• What are the roles, responsibilities, and delegation of authorities of personnel involved
in the design, development, deployment, assessment and monitoring of the AI system?

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• Who is accountable for the ethical considerations during all stages of the AI lifecycle?
• Who will be responsible for maintaining, re-verifying, monitoring, and updating this AI
once deployed?
• Are the responsibilities of the personnel involved in the various AI governance
processes clearly defined?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
National Academies of Sciences, Engineering, and Medicine. Human-AI Teaming: State-of-
the-Art and Research Needs. 2022.

Inioluwa Deborah Raji and Jingying Yang. "ABOUT ML: Annotation and Benchmarking on
Understanding and Transparency of Machine Learning Lifecycles." arXiv preprint,
submitted January 8, 2020.

Andrew Smith. "Using Artificial Intelligence and Algorithms." Federal Trade Commission
Business Blog, April 8, 2020.

Board of Governors of the Federal Reserve System. “SR 11-7: Guidance on Model Risk
Management.” April 4, 2011.

Joshua A. Kroll. “Outlining Traceability: A Principle for Operationalizing Accountability in


Computing Systems.” FAccT '21: Proceedings of the 2021 ACM Conference on Fairness,
Accountability, and Transparency, March 1, 2021, 758–71.

Jennifer Cobbe, Michelle Seng Lee, and Jatinder Singh. “Reviewable Automated Decision-
Making: A Framework for Accountable Algorithmic Systems.” FAccT '21: Proceedings of the
2021 ACM Conference on Fairness, Accountability, and Transparency, March 1, 2021, 598–
609.

MEASURE 2.9
The AI model is explained, validated, and documented, and AI system output is interpreted
within its context – as identified in the MAP function – and to inform responsible use and
governance.

About
Explainability and interpretability assist those operating or overseeing an AI system, as well
as users of an AI system, to gain deeper insights into the functionality and trustworthiness
of the system, including its outputs.

Explainable and interpretable AI systems offer information that help end users understand
the purposes and potential impact of an AI system. Risk from lack of explainability may be

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managed by describing how AI systems function, with descriptions tailored to individual
differences such as the user’s role, knowledge, and skill level. Explainable systems can be
debugged and monitored more easily, and they lend themselves to more thorough
documentation, audit, and governance.

Risks to interpretability often can be addressed by communicating a description of why

an AI system made a particular prediction or recommendation.

Transparency, explainability, and interpretability are distinct characteristics that support

each other. Transparency can answer the question of “what happened”. Explainability can
answer the question of “how” a decision was made in the system. Interpretability can
answer the question of “why” a decision was made by the system and its

meaning or context to the user.

Suggested Actions
• Verify systems are developed to produce explainable models, post-hoc explanations and
audit logs.
• When possible or available, utilize approaches that are inherently explainable, such as
traditional and penalized generalized linear models , decision trees, nearest-neighbor
and prototype-based approaches, rule-based models, generalized additive models ,
explainable boosting machines and neural additive models.
• Test explanation methods and resulting explanations prior to deployment to gain
feedback from relevant AI actors, end users, and potentially impacted individuals or
groups about whether explanations are accurate, clear, and understandable.
• Document AI model details including model type (e.g., convolutional neural network,
reinforcement learning, decision tree, random forest, etc.) data features, training
algorithms, proposed uses, decision thresholds, training data, evaluation data, and
ethical considerations.
• Establish, document, and report performance and error metrics across demographic
groups and other segments relevant to the deployment context.
• Explain systems using a variety of methods, e.g., visualizations, model extraction,
feature importance, and others. Since explanations may not accurately summarize
complex systems, test explanations according to properties such as fidelity, consistency,
robustness, and interpretability.
• Assess the characteristics of system explanations according to properties such as
fidelity (local and global), ambiguity, interpretability, interactivity, consistency, and
resilience to attack/manipulation.
• Test the quality of system explanations with end-users and other groups.
• Secure model development processes to avoid vulnerability to external manipulation
such as gaming explanation processes.
• Test for changes in models over time, including for models that adjust in response to
production data.

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• Use transparency tools such as data statements and model cards to document
explanatory and validation information.

Transparency & Documentation

Organizations can document the following


• Given the purpose of the AI, what level of explainability or interpretability is required
for how the AI made its determination?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• How has the entity documented the AI system’s data provenance, including sources,
origins, transformations, augmentations, labels, dependencies, constraints, and
metadata?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020.

References
Chaofan Chen, Oscar Li, Chaofan Tao, Alina Jade Barnett, Jonathan Su, and Cynthia Rudin.
"This Looks Like That: Deep Learning for Interpretable Image Recognition." arXiv preprint,
submitted December 28, 2019.

Cynthia Rudin. "Stop Explaining Black Box Machine Learning Models for High Stakes
Decisions and Use Interpretable Models Instead." arXiv preprint, submitted September 22,
2019.

David A. Broniatowski. "NISTIR 8367 Psychological Foundations of Explainability and


Interpretability in Artificial Intelligence. National Institute of Standards and Technology
(NIST), 2021.

Alejandro Barredo Arrieta, Natalia Díaz-Rodríguez, Javier Del Ser, Adrien Bennetot, Siham
Tabik, Alberto Barbado, Salvador Garcia, et al. “Explainable Artificial Intelligence (XAI):
Concepts, Taxonomies, Opportunities, and Challenges Toward Responsible AI.” Information
Fusion 58 (June 2020): 82–115.

Zana Buçinca, Phoebe Lin, Krzysztof Z. Gajos, and Elena L. Glassman. “Proxy Tasks and
Subjective Measures Can Be Misleading in Evaluating Explainable AI Systems.” IUI '20:

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Proceedings of the 25th International Conference on Intelligent User Interfaces, March 17,
2020, 454–64.

P. Jonathon Phillips, Carina A. Hahn, Peter C. Fontana, Amy N. Yates, Kristen Greene, David
A. Broniatowski, and Mark A. Przybocki. "NISTIR 8312 Four Principles of Explainable
Artificial Intelligence." National Institute of Standards and Technology (NIST), September
2021.

Margaret Mitchell, Simone Wu, Andrew Zaldivar, Parker Barnes, Lucy Vasserman, Ben
Hutchinson, Elena Spitzer, Inioluwa Deborah Raji, and Timnit Gebru. “Model Cards for
Model Reporting.” FAT *19: Proceedings of the Conference on Fairness, Accountability, and
Transparency, January 2019, 220–29.

Ke Yang, Julia Stoyanovich, Abolfazl Asudeh, Bill Howe, HV Jagadish, and Gerome Miklau. “A
Nutritional Label for Rankings.” SIGMOD '18: Proceedings of the 2018 International
Conference on Management of Data, May 27, 2018, 1773–76.

Marco Tulio Ribeiro, Sameer Singh, and Carlos Guestrin. "'Why Should I Trust You?':
Explaining the Predictions of Any Classifier." arXiv preprint, submitted August 9, 2016.

Scott M. Lundberg and Su-In Lee. "A unified approach to interpreting model predictions."
NIPS'17: Proceedings of the 31st International Conference on Neural Information
Processing Systems, December 4, 2017, 4768-4777.

Dylan Slack, Sophie Hilgard, Emily Jia, Sameer Singh, and Himabindu Lakkaraju. “Fooling
LIME and SHAP: Adversarial Attacks on Post Hoc Explanation Methods.” AIES '20:
Proceedings of the AAAI/ACM Conference on AI, Ethics, and Society, February 7, 2020, 180–
86.

David Alvarez-Melis and Tommi S. Jaakkola. "Towards robust interpretability with self-
explaining neural networks." NIPS'18: Proceedings of the 32nd International Conference on
Neural Information Processing Systems, December 3, 2018, 7786-7795.

FinRegLab, Laura Biattner, and Jann Spiess. "Machine Learning Explainability & Fairness:
Insights from Consumer Lending." FinRegLab, April 2022.

Miguel Ferreira, Muhammad Bilal Zafar, and Krishna P. Gummadi. "The Case for Temporal
Transparency: Detecting Policy Change Events in Black-Box Decision Making Systems."
arXiv preprint, submitted October 31, 2016.

Himabindu Lakkaraju, Ece Kamar, Rich Caruana, and Jure Leskovec. "Interpretable &
Explorable Approximations of Black Box Models." arXiv preprint, July 4, 2017.

Software Resources
• SHAP
• LIME
• Interpret

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• PiML
• Iml
• Dalex

MEASURE 2.10
Privacy risk of the AI system – as identified in the MAP function – is examined and
documented.

About
Privacy refers generally to the norms and practices that help to safeguard human autonomy,
identity, and dignity. These norms and practices typically address freedom from intrusion,
limiting observation, or individuals’ agency to consent to disclosure or control of facets of

their identities (e.g., body, data, reputation).

Privacy values such as anonymity, confidentiality, and control generally should guide
choices for AI system design, development, and deployment. Privacy-related risks may
influence security, bias, and transparency and come with tradeoffs with these other
characteristics. Like safety and security, specific technical features of an AI system may
promote or reduce privacy. AI systems can also present new risks to privacy by allowing
inference to identify individuals or previously private information about individuals.

Privacy-enhancing technologies (“PETs”) for AI, as well as data minimizing methods such as
de-identification and aggregation for certain model outputs, can support design for privacy-
enhanced AI systems. Under certain conditions such as data sparsity, privacy enhancing
techniques can result in a loss in accuracy, impacting decisions about fairness and other
values in certain domains.

Suggested Actions
• Specify privacy-related values, frameworks, and attributes that are applicable in the
context of use through direct engagement with end users and potentially impacted
groups and communities.
• Document collection, use, management, and disclosure of personally sensitive
information in datasets, in accordance with privacy and data governance policies
• Quantify privacy-level data aspects such as the ability to identify individuals or groups
(e.g. k-anonymity metrics, l-diversity, t-closeness).
• Establish and document protocols (authorization, duration, type) and access controls
for training sets or production data containing personally sensitive information, in
accordance with privacy and data governance policies.
• Monitor internal queries to production data for detecting patterns that isolate personal
records.
• Monitor PSI disclosures and inference of sensitive or legally protected attributes
• Use privacy-enhancing techniques such as differential privacy, when publicly sharing
dataset information.

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• Collaborate with privacy experts, AI end users and operators, and other domain experts
to determine optimal differential privacy metrics within contexts of use.

Transparency & Documentation

Organizations can document the following


• Did your organization implement accountability-based practices in data management
and protection (e.g. the PDPA and OECD Privacy Principles)?
• What assessments has the entity conducted on data security and privacy impacts
associated with the AI system?
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• Does the dataset contain information that might be considered sensitive or confidential?
(e.g., personally identifying information)
• If it relates to people, could this dataset expose people to harm or legal action? (e.g.,
financial, social or otherwise) What was done to mitigate or reduce the potential for
harm?

AI Transparency Resources
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020. (
• Datasheets for Datasets.

References
Kaitlin R. Boeckl and Naomi B. Lefkovitz. "NIST Privacy Framework: A Tool for Improving
Privacy Through Enterprise Risk Management, Version 1.0." National Institute of Standards
and Technology (NIST), January 16, 2020.

Latanya Sweeney. “K-Anonymity: A Model for Protecting Privacy.” International Journal of


Uncertainty, Fuzziness and Knowledge-Based Systems 10, no. 5 (2002): 557–70.

Ashwin Machanavajjhala, Johannes Gehrke, Daniel Kifer, and Muthuramakrishnan


Venkitasubramaniam. “L-Diversity: Privacy beyond K-Anonymity.” 22nd International
Conference on Data Engineering (ICDE'06), 2006.

Ninghui Li, Tiancheng Li, and Suresh Venkatasubramanian. "CERIAS Tech Report 2007-78 t-
Closeness: Privacy Beyond k-Anonymity and -Diversity." Center for Education and Research,
Information Assurance and Security, Purdue University, 2001.

J. Domingo-Ferrer and J. Soria-Comas. "From t-closeness to differential privacy and vice


versa in data anonymization." arXiv preprint, submitted December 21, 2015.

Joseph Near, David Darais, and Kaitlin Boeckly. "Differential Privacy for Privacy-Preserving
Data Analysis: An Introduction to our Blog Series." National Institute of Standards and
Technology (NIST), July 27, 2020.

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Cynthia Dwork. “Differential Privacy.” Automata, Languages and Programming, 2006, 1–12.

Zhanglong Ji, Zachary C. Lipton, and Charles Elkan. "Differential Privacy and Machine
Learning: a Survey and Review." arXiv preprint, submitted December 24,2014.

Michael B. Hawes. "Implementing Differential Privacy: Seven Lessons From the 2020 United
States Census." Harvard Data Science Review 2, no. 2 (2020).

Harvard University Privacy Tools Project. “Differential Privacy.” Harvard University, n.d.

John M. Abowd, Robert Ashmead, Ryan Cumings-Menon, Simson Garfinkel, Micah Heineck,
Christine Heiss, Robert Johns, Daniel Kifer, Philip Leclerc, Ashwin Machanavajjhala, Brett
Moran, William Matthew Spence Sexton and Pavel Zhuravlev. "The 2020 Census Disclosure
Avoidance System TopDown Algorithm." United States Census Bureau, April 7, 2022.

Nicolas Papernot and Abhradeep Guha Thakurta. "How to deploy machine learning with
differential privacy." National Institute of Standards and Technology (NIST), December 21,
2021.

Claire McKay Bowen. "Utility Metrics for Differential Privacy: No One-Size-Fits-All." National
Institute of Standards and Technology (NIST), November 29, 2021.

Helen Nissenbaum. "Contextual Integrity Up and Down the Data Food Chain." Theoretical
Inquiries in Law 20, L. 221 (2019): 221-256.

Sebastian Benthall, Seda Gürses, and Helen Nissenbaum. “Contextual Integrity through the
Lens of Computer Science.” Foundations and Trends in Privacy and Security 2, no. 1
(December 22, 2017): 1–69.

Jenifer Sunrise Winter and Elizabeth Davidson. “Big Data Governance of Personal Health
Information and Challenges to Contextual Integrity.” The Information Society: An
International Journal 35, no. 1 (2019): 36–51.

MEASURE 2.11
Fairness and bias – as identified in the MAP function – is evaluated and results are
documented.

About
Fairness in AI includes concerns for equality and equity by addressing issues such as
harmful bias and discrimination. Standards of fairness can be complex and difficult to define
because perceptions of fairness differ among cultures and may shift depending on
application. Organizations’ risk management efforts will be enhanced by recognizing and
considering these differences. Systems in which harmful biases are mitigated are not
necessarily fair. For example, systems in which predictions are somewhat balanced across
demographic groups may still be inaccessible to individuals with disabilities or affected by
the digital divide or may exacerbate existing disparities or systemic biases.

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Bias is broader than demographic balance and data representativeness. NIST has identified
three major categories of AI bias to be considered and managed: systemic, computational
and statistical, and human-cognitive. Each of these can occur in the absence of prejudice,
partiality, or discriminatory intent.

• Systemic bias can be present in AI datasets, the organizational norms, practices, and
processes across the AI lifecycle, and the broader society that uses AI systems.
• Computational and statistical biases can be present in AI datasets and algorithmic
processes, and often stem from systematic errors due to non-representative samples.
• Human-cognitive biases relate to how an individual or group perceives AI system
information to make a decision or fill in missing information, or how humans think
about purposes and functions of an AI system. Human-cognitive biases are omnipresent
in decision-making processes across the AI lifecycle and system use, including the
design, implementation, operation, and maintenance of AI.

Bias exists in many forms and can become ingrained in the automated systems that help
make decisions about our lives. While bias is not always a negative phenomenon, AI systems
can potentially increase the speed and scale of biases and perpetuate and amplify harms to
individuals, groups, communities, organizations, and society.

Suggested Actions
• Conduct fairness assessments to manage computational and statistical forms of bias
which include the following steps:

• Evaluate underlying data distributions and employ sensitivity analysis during


the analysis of quantified harms.
• Evaluate quality metrics including false positive rates and false negative rates.
• Consider biases affecting small groups, within-group or intersectional
communities, or single individuals.

• Understand and consider sources of bias in training and TEVV data:


• Leverage impact assessments to identify and classify system impacts and harms to end
users, other individuals, and groups with input from potentially impacted communities.
• Identify the classes of individuals, groups, or environmental ecosystems which might be
impacted through direct engagement with potentially impacted communities.
• Evaluate systems in regards to disability inclusion, including consideration of disability
status in bias testing, and discriminatory screen out processes that may arise from non-
inclusive design or deployment decisions.
• Develop objective functions in consideration of systemic biases, in-group/out-group
dynamics.
• Use context-specific fairness metrics to examine how system performance varies across
groups, within groups, and/or for intersecting groups. Metrics may include statistical
parity, error-rate equality, statistical parity difference, equal opportunity difference,

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average absolute odds difference, standardized mean difference, percentage point
differences.
• Customize fairness metrics to specific context of use to examine how system
performance and potential harms vary within contextual norms.
• Define acceptable levels of difference in performance in accordance with established
organizational governance policies, business requirements, regulatory compliance, legal
frameworks, and ethical standards within the context of use
• Define the actions to be taken if disparity levels rise above acceptable levels.
• Identify groups within the expected population that may require disaggregated analysis,
in collaboration with impacted communities.
• Leverage experts with knowledge in the specific context of use to investigate substantial
measurement differences and identify root causes for those differences.
• Monitor system outputs for performance or bias issues that exceed established
tolerance levels.
• Ensure periodic model updates; test and recalibrate with updated and more
representative data to stay within acceptable levels of difference.
• Apply pre-processing data transformations to address factors related to demographic
balance and data representativeness.
• Apply in-processing to balance model performance quality with bias considerations.
• Apply post-processing mathematical/computational techniques to model results in
close collaboration with impact assessors, socio-technical experts, and other AI actors
with expertise in the context of use.
• Apply model selection approaches with transparent and deliberate consideration of bias
management and other trustworthy characteristics.
• Collect and share information about differences in outcomes for the identified groups.
• Consider mediations to mitigate differences, especially those that can be traced to past
patterns of unfair or biased human decision making.
• Utilize human-centered design practices to generate deeper focus on societal impacts
and counter human-cognitive biases within the AI lifecycle.
• Evaluate practices along the lifecycle to identify potential sources of human-cognitive
bias such as availability, observational, and confirmation bias, and to make implicit
decision making processes more explicit and open to investigation.
• Work with human factors experts to evaluate biases in the presentation of system
output to end users, operators and practitioners.
• Utilize processes to enhance contextual awareness, such as diverse internal staff and
stakeholder engagement.

Transparency & Documentation

Organizations can document the following


• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?

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• If it relates to people, does it unfairly advantage or disadvantage a particular social
group? In what ways? How was this mitigated?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• How has the entity identified and mitigated potential impacts of bias in the data,
including inequitable or discriminatory outcomes?
• To what extent has the entity identified and mitigated potential bias—statistical,
contextual, and historical—in the data?
• Were adversarial machine learning approaches considered or used for measuring bias
(e.g.: prompt engineering, adversarial models)

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework- WEF - Companion to the
Model AI Governance Framework, 2020.
• Datasheets for Datasets.

References
Ali Hasan, Shea Brown, Jovana Davidovic, Benjamin Lange, and Mitt Regan. “Algorithmic
Bias and Risk Assessments: Lessons from Practice.” Digital Society 1 (2022).

Richard N. Landers and Tara S. Behrend. “Auditing the AI Auditors: A Framework for
Evaluating Fairness and Bias in High Stakes AI Predictive Models.” American Psychologist
78, no. 1 (2023): 36–49.

Ninareh Mehrabi, Fred Morstatter, Nripsuta Saxena, Kristina Lerman, and Aram Galstyan. “A
Survey on Bias and Fairness in Machine Learning.” ACM Computing Surveys 54, no. 6 (July
2021): 1–35.

Michele Loi and Christoph Heitz. “Is Calibration a Fairness Requirement?” FAccT '22: 2022
ACM Conference on Fairness, Accountability, and Transparency, June 2022, 2026–34.

Shea Brown, Ryan Carrier, Merve Hickok, and Adam Leon Smith. “Bias Mitigation in Data
Sets.” SocArXiv, July 8, 2021.

Reva Schwartz, Apostol Vassilev, Kristen Greene, Lori Perine, Andrew Burt, and Patrick Hall.
"NIST Special Publication 1270 Towards a Standard for Identifying and Managing Bias in
Artificial Intelligence." National Institute of Standards and Technology (NIST), 2022.

Microsoft Research. “AI Fairness Checklist.” Microsoft, February 7, 2022.

Samir Passi and Solon Barocas. “Problem Formulation and Fairness.” FAT* '19: Proceedings
of the Conference on Fairness, Accountability, and Transparency, January 2019, 39–48.

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Jade S. Franklin, Karan Bhanot, Mohamed Ghalwash, Kristin P. Bennett, Jamie McCusker, and
Deborah L. McGuinness. “An Ontology for Fairness Metrics.” AIES '22: Proceedings of the
2022 AAAI/ACM Conference on AI, Ethics, and Society, July 2022, 265–75.

Zhang, B., Lemoine, B., & Mitchell, M. (2018). Mitigating Unwanted Biases with Adversarial
Learning. Proceedings of the 2018 AAAI/ACM Conference on AI, Ethics, and Society.
https://arxiv.org/pdf/1801.07593.pdf

Ganguli, D., et al. (2023). The Capacity for Moral Self-Correction in Large Language Models.
arXiv. https://arxiv.org/abs/2302.07459

Arvind Narayanan. “Tl;DS - 21 Fairness Definition and Their Politics by Arvind Narayanan.”
Dora's world, July 19, 2019.

Ben Green. “Escaping the Impossibility of Fairness: From Formal to Substantive Algorithmic
Fairness.” Philosophy and Technology 35, no. 90 (October 8, 2022).

Alexandra Chouldechova. “Fair Prediction with Disparate Impact: A Study of Bias in


Recidivism Prediction Instruments.” Big Data 5, no. 2 (June 1, 2017): 153–63.

Sina Fazelpour and Zachary C. Lipton. “Algorithmic Fairness from a Non-Ideal Perspective.”
AIES '20: Proceedings of the AAAI/ACM Conference on AI, Ethics, and Society, February 7,
2020, 57–63.

Hemank Lamba, Kit T. Rodolfa, and Rayid Ghani. “An Empirical Comparison of Bias
Reduction Methods on Real-World Problems in High-Stakes Policy Settings.” ACM SIGKDD
Explorations Newsletter 23, no. 1 (May 29, 2021): 69–85.

ISO. “ISO/IEC TR 24027:2021 Information technology — Artificial intelligence (AI) — Bias


in AI systems and AI aided decision making.” ISO Standards, November 2021.

Shari Trewin. "AI Fairness for People with Disabilities: Point of View." arXiv preprint,
submitted November 26, 2018.

MathWorks. “Explore Fairness Metrics for Credit Scoring Model.” MATLAB & Simulink,
2023.

Abigail Z. Jacobs and Hanna Wallach. “Measurement and Fairness.” FAccT '21: Proceedings
of the 2021 ACM Conference on Fairness, Accountability, and Transparency, March 2021,
375–85.

Tolga Bolukbasi, Kai-Wei Chang, James Zou, Venkatesh Saligrama, and Adam Kalai.
"Quantifying and Reducing Stereotypes in Word Embeddings." arXiv preprint, submitted
June 20, 2016.

Aylin Caliskan, Joanna J. Bryson, and Arvind Narayanan. “Semantics Derived Automatically
from Language Corpora Contain Human-Like Biases.” Science 356, no. 6334 (April 14,
2017): 183–86.

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ience.aal4230)

Sina Fazelpour and Maria De-Arteaga. “Diversity in Sociotechnical Machine Learning


Systems.” Big Data and Society 9, no. 1 (2022).

Fairlearn. “Fairness in Machine Learning.” Fairlearn 0.8.0 Documentation, n.d.

Safiya Umoja Noble. Algorithms of Oppression: How Search Engines Reinforce Racism. New
York, NY: New York University Press, 2018.

Ziad Obermeyer, Brian Powers, Christine Vogeli, and Sendhil Mullainathan. “Dissecting
Racial Bias in an Algorithm Used to Manage the Health of Populations.” Science 366, no.
6464 (October 25, 2019): 447–53.

Alekh Agarwal, Alina Beygelzimer, Miroslav Dudík, John Langford, and Hanna Wallach. "A
Reductions Approach to Fair Classification." arXiv preprint, submitted July 16, 2018.

Moritz Hardt, Eric Price, and Nathan Srebro. "Equality of Opportunity in Supervised
Learning." arXiv preprint, submitted October 7, 2016.

Alekh Agarwal, Miroslav Dudik, Zhiwei Steven Wu. "Fair Regression: Quantitative
Definitions and Reduction-Based Algorithms." Proceedings of the 36th International
Conference on Machine Learning, PMLR 97:120-129, 2019.

Andrew D. Selbst, Danah Boyd, Sorelle A. Friedler, Suresh Venkatasubramanian, and Janet
Vertesi. “Fairness and Abstraction in Sociotechnical Systems.” FAT* '19: Proceedings of the
Conference on Fairness, Accountability, and Transparency, January 29, 2019, 59–68.

Matthew Kay, Cynthia Matuszek, and Sean A. Munson. “Unequal Representation and Gender
Stereotypes in Image Search Results for Occupations.” CHI '15: Proceedings of the 33rd
Annual ACM Conference on Human Factors in Computing Systems, April 18, 2015, 3819–28.

Software Resources
• aequitas

- AI Fairness 360:

• Python
• R
• algofairness
• fairlearn
• fairml
• fairmodels
• fairness
• solas-ai-disparity
• tensorflow/fairness-indicators
• Themis

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MEASURE 2.12
Environmental impact and sustainability of AI model training and management activities –
as identified in the MAP function – are assessed and documented.

About
Large-scale, high-performance computational resources used by AI systems for training and
operation can contribute to environmental impacts. Direct negative impacts to the
environment from these processes are related to energy consumption, water consumption,
and greenhouse gas (GHG) emissions. The OECD has identified metrics for each type of
negative direct impact.

Indirect negative impacts to the environment reflect the complexity of interactions between
human behavior, socio-economic systems, and the environment and can include induced
consumption and “rebound effects”, where efficiency gains are offset by accelerated
resource consumption.

Other AI related environmental impacts can arise from the production of computational
equipment and networks (e.g. mining and extraction of raw materials), transporting
hardware, and electronic waste recycling or disposal.

Suggested Actions
• Include environmental impact indicators in AI system design and development plans,
including reducing consumption and improving efficiencies.
• Identify and implement key indicators of AI system energy and water consumption and
efficiency, and/or GHG emissions.
• Establish measurable baselines for sustainable AI system operation in accordance with
organizational policies, regulatory compliance, legal frameworks, and environmental
protection and sustainability norms.
• Assess tradeoffs between AI system performance and sustainable operations in
accordance with organizational principles and policies, regulatory compliance, legal
frameworks, and environmental protection and sustainability norms.
• Identify and establish acceptable resource consumption and efficiency, and GHG
emissions levels, along with actions to be taken if indicators rise above acceptable
levels.
• Estimate AI system emissions levels throughout the AI lifecycle via carbon calculators or
similar process.

Transparency & Documentation

Organizations can document the following


• Are greenhouse gas emissions, and energy and water consumption and efficiency
tracked within the organization?
• Are deployed AI systems evaluated for potential upstream and downstream
environmental impacts (e.g., increased consumption, increased emissions, etc.)?

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• Could deployed AI systems cause environmental incidents, e.g., air or water pollution
incidents, toxic spills, fires or explosions?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• Datasheets for Datasets.

References
Organisation for Economic Co-operation and Development (OECD). "Measuring the
environmental impacts of artificial intelligence compute and applications: The AI footprint.”
OECD Digital Economy Papers, No. 341, OECD Publishing, Paris.

Victor Schmidt, Alexandra Luccioni, Alexandre Lacoste, and Thomas Dandres. “Machine
Learning CO2 Impact Calculator.” ML CO2 Impact, n.d.

Alexandre Lacoste, Alexandra Luccioni, Victor Schmidt, and Thomas Dandres. "Quantifying
the Carbon Emissions of Machine Learning." arXiv preprint, submitted November 4, 2019.

Matthew Hutson. “Measuring AI’s Carbon Footprint: New Tools Track and Reduce
Emissions from Machine Learning.” IEEE Spectrum, November 22, 2022.

Association for Computing Machinery (ACM). "TechBriefs: Computing and Climate Change."
ACM Technology Policy Council, November 2021.

Roy Schwartz, Jesse Dodge, Noah A. Smith, and Oren Etzioni. “Green AI.” Communications of
the ACM 63, no. 12 (December 2020): 54–63.

MEASURE 2.13
Effectiveness of the employed TEVV metrics and processes in the MEASURE function are
evaluated and documented.

About
The development of metrics is a process often considered to be objective but, as a human
and organization driven endeavor, can reflect implicit and systemic biases, and may
inadvertently reflect factors unrelated to the target function. Measurement approaches can
be oversimplified, gamed, lack critical nuance, become used and relied upon in unexpected
ways, fail to account for differences in affected groups and contexts.

Revisiting the metrics chosen in Measure 2.1 through 2.12 in a process of continual
improvement can help AI actors to evaluate and document metric effectiveness and make
necessary course corrections.

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Suggested Actions
• Review selected system metrics and associated TEVV processes to determine if they are
able to sustain system improvements, including the identification and removal of errors.
• Regularly evaluate system metrics for utility, and consider descriptive approaches in
place of overly complex methods.
• Review selected system metrics for acceptability within the end user and impacted
community of interest.
• Assess effectiveness of metrics for identifying and measuring risks.

Transparency & Documentation

Organizations can document the following


• To what extent does the system/entity consistently measure progress towards stated
goals and objectives?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• What corrective actions has the entity taken to enhance the quality, accuracy, reliability,
and representativeness of the data?
• To what extent are the model outputs consistent with the entity’s values and principles
to foster public trust and equity?
• How will the accuracy or appropriate performance metrics be assessed?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Arvind Narayanan. "The limits of the quantitative approach to discrimination." 2022 James
Baldwin lecture, Princeton University, October 11, 2022.

Devansh Saxena, Karla Badillo-Urquiola, Pamela J. Wisniewski, and Shion Guha. “A Human-
Centered Review of Algorithms Used within the U.S. Child Welfare System.” CHI ‘20:
Proceedings of the 2020 CHI Conference on Human Factors in Computing Systems, April 23,
2020, 1–15.

Rachel Thomas and David Uminsky. “Reliance on Metrics Is a Fundamental Challenge for
AI.” Patterns 3, no. 5 (May 13, 2022): 100476.

Momin M. Malik. "A Hierarchy of Limitations in Machine Learning." arXiv preprint,


submitted February 29, 2020.

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MEASURE 3.1
Approaches, personnel, and documentation are in place to regularly identify and track
existing, unanticipated, and emergent AI risks based on factors such as intended and actual
performance in deployed contexts.

About
For trustworthy AI systems, regular system monitoring is carried out in accordance with
organizational governance policies, AI actor roles and responsibilities, and within a culture
of continual improvement. If and when emergent or complex risks arise, it may be
necessary to adapt internal risk management procedures, such as regular monitoring, to
stay on course. Documentation, resources, and training are part of an overall strategy to
support AI actors as they investigate and respond to AI system errors, incidents or negative
impacts.

Suggested Actions
• Compare AI system risks with:
• Compare end user and community feedback about deployed AI systems to internal
measures of system performance.
• Assess effectiveness of metrics for identifying and measuring emergent risks.
• Measure error response times and track response quality.
• Elicit and track feedback from AI actors in user support roles about the type of metrics,
explanations and other system information required for fulsome resolution of system
issues. Consider:
• Elicit and track feedback from AI actors in incident response and support roles about
the adequacy of staffing and resources to perform their duties in an effective and timely
manner.

Transparency & Documentation

Organizations can document the following


• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• What metrics has the entity developed to measure performance of the AI system,
including error logging?
• To what extent do the metrics provide accurate and useful measure of performance?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

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• WEF Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations

References
ISO. "ISO 9241-210:2019 Ergonomics of human-system interaction — Part 210: Human-
centred design for interactive systems." 2nd ed. ISO Standards, July 2019.

Larysa Visengeriyeva, et al. “Awesome MLOps.“ GitHub.

MEASURE 3.2
Risk tracking approaches are considered for settings where AI risks are difficult to assess
using currently available measurement techniques or where metrics are not yet available.

About
Risks identified in the Map function may be complex, emerge over time, or difficult to
measure. Systematic methods for risk tracking, including novel measurement approaches,
can be established as part of regular monitoring and improvement processes.

Suggested Actions
• Establish processes for tracking emergent risks that may not be measurable with
current approaches. Some processes may include:

• entered design approaches.

• Identify AI actors responsible for tracking emergent risks and inventory methods.
• Determine and document the rate of occurrence and severity level for complex or
difficult-to-measure risks when:

Transparency & Documentation

Organizations can document the following


• Who is ultimately responsible for the decisions of the AI and is this person aware of the
intended uses and limitations of the analytic?
• Who will be responsible for maintaining, re-verifying, monitoring, and updating this AI
once deployed?
• To what extent does the entity communicate its AI strategic goals and objectives to the
community of stakeholders?
• Given the purpose of this AI, what is an appropriate interval for checking whether it is
still accurate, unbiased, explainable, etc.? What are the checks for this model?
• If anyone believes that the AI no longer meets this ethical framework, who will be
responsible for receiving the concern and as appropriate investigating and remediating
the issue? Do they have authority to modify, limit, or stop the use of the AI?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.

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• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
ISO. "ISO 9241-210:2019 Ergonomics of human-system interaction — Part 210: Human-
centred design for interactive systems." 2nd ed. ISO Standards, July 2019.

Mark C. Paulk, Bill Curtis, Mary Beth Chrissis, and Charles V. Weber. “Capability Maturity
Model, Version 1.1.” IEEE Software 10, no. 4 (1993): 18–27.

Jeff Patton, Peter Economy, Martin Fowler, Alan Cooper, and Marty Cagan. User Story
Mapping: Discover the Whole Story, Build the Right Product. O'Reilly, 2014.

Rumman Chowdhury and Jutta Williams. "Introducing Twitter’s first algorithmic bias
bounty challenge." Twitter Engineering Blog, July 30, 2021.

HackerOne. "Twitter Algorithmic Bias." HackerOne, August 8, 2021.

Josh Kenway, Camille François, Sasha Costanza-Chock, Inioluwa Deborah Raji, and Joy
Buolamwini. "Bug Bounties for Algorithmic Harms?" Algorithmic Justice League, January
2022.

Microsoft. “Community Jury.” Microsoft Learn's Azure Application Architecture Guide, 2023.

Margarita Boyarskaya, Alexandra Olteanu, and Kate Crawford. "Overcoming Failures of


Imagination in AI Infused System Development and Deployment." arXiv preprint, submitted
December 10, 2020.

MEASURE 3.3
Feedback processes for end users and impacted communities to report problems and
appeal system outcomes are established and integrated into AI system evaluation metrics.

About
Assessing impact is a two-way effort. Many AI system outcomes and impacts may not be
visible or recognizable to AI actors across the development and deployment dimensions of
the AI lifecycle, and may require direct feedback about system outcomes from the
perspective of end users and impacted groups.

Feedback can be collected indirectly, via systems that are mechanized to collect errors and
other feedback from end users and operators

Metrics and insights developed in this sub-category feed into Manage 4.1 and 4.2.

Suggested Actions
• Measure efficacy of end user and operator error reporting processes.
• Categorize and analyze type and rate of end user appeal requests and results.
• Measure feedback activity participation rates and awareness of feedback activity
availability.

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• Utilize feedback to analyze measurement approaches and determine subsequent
courses of action.
• Evaluate measurement approaches to determine efficacy for enhancing organizational
understanding of real world impacts.
• Analyze end user and community feedback in close collaboration with domain experts.

Transparency & Documentation

Organizations can document the following


• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• Did your organization address usability problems and test whether user interfaces
served their intended purposes?
• How easily accessible and current is the information available to external stakeholders?
• What type of information is accessible on the design, operations, and limitations of the
AI system to external stakeholders, including end users, consumers, regulators, and
individuals impacted by use of the AI system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• WEF Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations

References
Sasha Costanza-Chock. Design Justice: Community-Led Practices to Build the Worlds We
Need. Cambridge: The MIT Press, 2020.

David G. Robinson. Voices in the Code: A Story About People, Their Values, and the
Algorithm They Made. New York: Russell Sage Foundation, 2022.

Fernando Delgado, Stephen Yang, Michael Madaio, and Qian Yang. "Stakeholder
Participation in AI: Beyond 'Add Diverse Stakeholders and Stir.'" arXiv preprint, submitted
November 1, 2021.

George Margetis, Stavroula Ntoa, Margherita Antona, and Constantine Stephanidis. “Human-
Centered Design of Artificial Intelligence.” In Handbook of Human Factors and Ergonomics,
edited by Gavriel Salvendy and Waldemar Karwowski, 5th ed., 1085–1106. John Wiley &
Sons, 2021.

Ben Shneiderman. Human-Centered AI. Oxford: Oxford University Press, 2022

Batya Friedman, David G. Hendry, and Alan Borning. “A Survey of Value Sensitive Design
Methods.” Foundations and Trends in Human-Computer Interaction 11, no. 2 (November
22, 2017): 63–125.

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Batya Friedman, Peter H. Kahn, Jr., and Alan Borning. "Value Sensitive Design: Theory and
Methods." University of Washington Department of Computer Science & Engineering
Technical Report 02-12-01, December 2002.

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, and Jacob Metcalf.
“Assembling Accountability: Algorithmic Impact Assessment for the Public Interest.” SSRN,
July 8, 2021.

Alexandra Reeve Givens, and Meredith Ringel Morris. “Centering Disability Perspectives in
Algorithmic Fairness, Accountability, & Transparency.” FAT* '20: Proceedings of the 2020
Conference on Fairness, Accountability, and Transparency, January 27, 2020, 684-84.

MEASURE 4.1
Measurement approaches for identifying AI risks are connected to deployment context(s)
and informed through consultation with domain experts and other end users. Approaches
are documented.

About
AI Actors carrying out TEVV tasks may have difficulty evaluating impacts within the system
context of use. AI system risks and impacts are often best described by end users and others
who may be affected by output and subsequent decisions. AI Actors can elicit feedback from
impacted individuals and communities via participatory engagement processes established
in Govern 5.1 and 5.2, and carried out in Map 1.6, 5.1, and 5.2.

Activities described in the Measure function enable AI actors to evaluate feedback from
impacted individuals and communities. To increase awareness of insights, feedback can be
evaluated in close collaboration with AI actors responsible for impact assessment, human-
factors, and governance and oversight tasks, as well as with other socio-technical domain
experts and researchers. To gain broader expertise for interpreting evaluation outcomes,
organizations may consider collaborating with advocacy groups and civil society
organizations.

Insights based on this type of analysis can inform TEVV-based decisions about metrics and
related courses of action.

Suggested Actions
• Support mechanisms for capturing feedback from system end users (including domain
experts, operators, and practitioners). Successful approaches are:
• Identify and document approaches
• Evaluate feedback from end users alongside evaluated feedback from impacted
communities (MEASURE 3.3).
• Utilize end user feedback to investigate how selected metrics and measurement
approaches interact with organizational and operational contexts.
• Analyze and document system-internal measurement processes in comparison to
collected end user feedback.

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• Identify and implement approaches to measure effectiveness and satisfaction with end
user elicitation techniques, and document results.

Transparency & Documentation

Organizations can document the following


• Did your organization address usability problems and test whether user interfaces
served their intended purposes?
• How will user and peer engagement be integrated into the model development process
and periodic performance review once deployed?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?
• To what extent are the established procedures effective in mitigating bias, inequity, and
other concerns resulting from the system?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.
• WEF Companion to the Model AI Governance Framework – Implementation and Self-
Assessment Guide for Organizations

References
Batya Friedman, and David G. Hendry. Value Sensitive Design: Shaping Technology with
Moral Imagination. Cambridge, MA: The MIT Press, 2019.

Batya Friedman, David G. Hendry, and Alan Borning. “A Survey of Value Sensitive Design
Methods.” Foundations and Trends in Human-Computer Interaction 11, no. 2 (November
22, 2017): 63–125.

Steven Umbrello, and Ibo van de Poel. “Mapping Value Sensitive Design onto AI for Social
Good Principles.” AI and Ethics 1, no. 3 (February 1, 2021): 283–96.

Karen Boyd. “Designing Up with Value-Sensitive Design: Building a Field Guide for Ethical
ML Development.” FAccT '22: 2022 ACM Conference on Fairness, Accountability, and
Transparency, June 20, 2022, 2069–82.

Janet Davis and Lisa P. Nathan. “Value Sensitive Design: Applications, Adaptations, and
Critiques.” In Handbook of Ethics, Values, and Technological Design, edited by Jeroen van
den Hoven, Pieter E. Vermaas, and Ibo van de Poel, January 1, 2015, 11–40.

Ben Shneiderman. Human-Centered AI. Oxford: Oxford University Press, 2022.

Shneiderman, Ben. “Human-Centered AI.” Issues in Science and Technology 37, no. 2
(2021): 56–61.

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Shneiderman, Ben. “Tutorial: Human-Centered AI: Reliable, Safe and Trustworthy.” IUI '21
Companion: 26th International Conference on Intelligent User Interfaces - Companion, April
14, 2021, 7–8.

George Margetis, Stavroula Ntoa, Margherita Antona, and Constantine Stephanidis. “Human-
Centered Design of Artificial Intelligence.” In Handbook of Human Factors and Ergonomics,
edited by Gavriel Salvendy and Waldemar Karwowski, 5th ed., 1085–1106. John Wiley &
Sons, 2021.

Caitlin Thompson. “Who's Homeless Enough for Housing? In San Francisco, an Algorithm
Decides.” Coda, September 21, 2021.

John Zerilli, Alistair Knott, James Maclaurin, and Colin Gavaghan. “Algorithmic Decision-
Making and the Control Problem.” Minds and Machines 29, no. 4 (December 11, 2019): 555–
78.

Fry, Hannah. Hello World: Being Human in the Age of Algorithms. New York: W.W. Norton &
Company, 2018.

Sasha Costanza-Chock. Design Justice: Community-Led Practices to Build the Worlds We


Need. Cambridge: The MIT Press, 2020.

David G. Robinson. Voices in the Code: A Story About People, Their Values, and the
Algorithm They Made. New York: Russell Sage Foundation, 2022.

Diane Hart, Gabi Diercks-O'Brien, and Adrian Powell. “Exploring Stakeholder Engagement in
Impact Evaluation Planning in Educational Development Work.” Evaluation 15, no. 3
(2009): 285–306.

Asit Bhattacharyya and Lorne Cummings. “Measuring Corporate Environmental


Performance – Stakeholder Engagement Evaluation.” Business Strategy and the
Environment 24, no. 5 (2013): 309–25.

Hendricks, Sharief, Nailah Conrad, Tania S. Douglas, and Tinashe Mutsvangwa. “A Modified
Stakeholder Participation Assessment Framework for Design Thinking in Health
Innovation.” Healthcare 6, no. 3 (September 2018): 191–96.

Fernando Delgado, Stephen Yang, Michael Madaio, and Qian Yang. "Stakeholder
Participation in AI: Beyond 'Add Diverse Stakeholders and Stir.'" arXiv preprint, submitted
November 1, 2021.

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, and Jacob Metcalf.
“Assembling Accountability: Algorithmic Impact Assessment for the Public Interest.” SSRN,
July 8, 2021.

131 of 137
Alexandra Reeve Givens, and Meredith Ringel Morris. “Centering Disability Perspectives in
Algorithmic Fairness, Accountability, & Transparency.” FAT* '20: Proceedings of the 2020
Conference on Fairness, Accountability, and Transparency, January 27, 2020, 684-84.

MEASURE 4.2
Measurement results regarding AI system trustworthiness in deployment context(s) and
across AI lifecycle are informed by input from domain experts and other relevant AI actors
to validate whether the system is performing consistently as intended. Results are
documented.

About
Feedback captured from relevant AI Actors can be evaluated in combination with output
from Measure 2.5 to 2.11 to determine if the AI system is performing within pre-defined
operational limits for validity and reliability, safety, security and resilience, privacy, bias
and fairness, explainability and interpretability, and transparency and accountability. This
feedback provides an additional layer of insight about AI system performance, including
potential misuse or reuse outside of intended settings.

Insights based on this type of analysis can inform TEVV-based decisions about metrics and
related courses of action.

Suggested Actions
• Integrate feedback from end users, operators, and affected individuals and communities
from Map function as inputs to assess AI system trustworthiness characteristics. Ensure
both positive and negative feedback is being assessed.
• Evaluate feedback in connection with AI system trustworthiness characteristics from
Measure 2.5 to 2.11.
• Evaluate feedback regarding end user satisfaction with, and confidence in, AI system
performance including whether output is considered valid and reliable, and explainable
and interpretable.
• Identify mechanisms to confirm/support AI system output (e.g. recommendations), and
end user perspectives about that output.
• Measure frequency of AI systems’ override decisions, evaluate and document results,
and feed insights back into continual improvement processes.
• Consult AI actors in impact assessment, human factors and socio-technical tasks to
assist with analysis and interpretation of results.

Transparency & Documentation

Organizations can document the following


• To what extent does the system/entity consistently measure progress towards stated
goals and objectives?
• What policies has the entity developed to ensure the use of the AI system is consistent
with its stated values and principles?

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• To what extent are the model outputs consistent with the entity’s values and principles
to foster public trust and equity?
• Given the purpose of the AI, what level of explainability or interpretability is required
for how the AI made its determination?
• To what extent can users or parties affected by the outputs of the AI system test the AI
system and provide feedback?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Batya Friedman, and David G. Hendry. Value Sensitive Design: Shaping Technology with
Moral Imagination. Cambridge, MA: The MIT Press, 2019.

Batya Friedman, David G. Hendry, and Alan Borning. “A Survey of Value Sensitive Design
Methods.” Foundations and Trends in Human-Computer Interaction 11, no. 2 (November
22, 2017): 63–125.

Steven Umbrello, and Ibo van de Poel. “Mapping Value Sensitive Design onto AI for Social
Good Principles.” AI and Ethics 1, no. 3 (February 1, 2021): 283–96.

Karen Boyd. “Designing Up with Value-Sensitive Design: Building a Field Guide for Ethical
ML Development.” FAccT '22: 2022 ACM Conference on Fairness, Accountability, and
Transparency, June 20, 2022, 2069–82.

Janet Davis and Lisa P. Nathan. “Value Sensitive Design: Applications, Adaptations, and
Critiques.” In Handbook of Ethics, Values, and Technological Design, edited by Jeroen van
den Hoven, Pieter E. Vermaas, and Ibo van de Poel, January 1, 2015, 11–40.

Ben Shneiderman. Human-Centered AI. Oxford: Oxford University Press, 2022.

Shneiderman, Ben. “Human-Centered AI.” Issues in Science and Technology 37, no. 2
(2021): 56–61.

Shneiderman, Ben. “Tutorial: Human-Centered AI: Reliable, Safe and Trustworthy.” IUI '21
Companion: 26th International Conference on Intelligent User Interfaces - Companion, April
14, 2021, 7–8.

George Margetis, Stavroula Ntoa, Margherita Antona, and Constantine Stephanidis. “Human-
Centered Design of Artificial Intelligence.” In Handbook of Human Factors and Ergonomics,
edited by Gavriel Salvendy and Waldemar Karwowski, 5th ed., 1085–1106. John Wiley &
Sons, 2021.

Caitlin Thompson. “Who's Homeless Enough for Housing? In San Francisco, an Algorithm
Decides.” Coda, September 21, 2021.

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John Zerilli, Alistair Knott, James Maclaurin, and Colin Gavaghan. “Algorithmic Decision-
Making and the Control Problem.” Minds and Machines 29, no. 4 (December 11, 2019): 555–
78.

Fry, Hannah. Hello World: Being Human in the Age of Algorithms. New York: W.W. Norton &
Company, 2018.

Sasha Costanza-Chock. Design Justice: Community-Led Practices to Build the Worlds We


Need. Cambridge: The MIT Press, 2020.

David G. Robinson. Voices in the Code: A Story About People, Their Values, and the
Algorithm They Made. New York: Russell Sage Foundation, 2022.

Diane Hart, Gabi Diercks-O'Brien, and Adrian Powell. “Exploring Stakeholder Engagement in
Impact Evaluation Planning in Educational Development Work.” Evaluation 15, no. 3
(2009): 285–306.

Asit Bhattacharyya and Lorne Cummings. “Measuring Corporate Environmental


Performance – Stakeholder Engagement Evaluation.” Business Strategy and the
Environment 24, no. 5 (2013): 309–25.

Hendricks, Sharief, Nailah Conrad, Tania S. Douglas, and Tinashe Mutsvangwa. “A Modified
Stakeholder Participation Assessment Framework for Design Thinking in Health
Innovation.” Healthcare 6, no. 3 (September 2018): 191–96.

Fernando Delgado, Stephen Yang, Michael Madaio, and Qian Yang. "Stakeholder
Participation in AI: Beyond 'Add Diverse Stakeholders and Stir.'" arXiv preprint, submitted
November 1, 2021.

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, and Jacob Metcalf.
“Assembling Accountability: Algorithmic Impact Assessment for the Public Interest.” SSRN,
July 8, 2021.

Alexandra Reeve Givens, and Meredith Ringel Morris. “Centering Disability Perspectives in
Algorithmic Fairness, Accountability, & Transparency.” FAT* '20: Proceedings of the 2020
Conference on Fairness, Accountability, and Transparency, January 27, 2020, 684-84.

MEASURE 4.3
Measurable performance improvements or declines based on consultations with relevant AI
actors including affected communities, and field data about context-relevant risks and
trustworthiness characteristics, are identified and documented.

About
TEVV activities conducted throughout the AI system lifecycle can provide baseline
quantitative measures for trustworthy characteristics. When combined with results from
Measure 2.5 to 2.11 and Measure 4.1 and 4.2, TEVV actors can maintain a comprehensive
view of system performance. These measures can be augmented through participatory

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engagement with potentially impacted communities or other forms of stakeholder
elicitation about AI systems’ impacts. These sources of information can allow AI actors to
explore potential adjustments to system components, adapt operating conditions, or
institute performance improvements.

Suggested Actions
• Develop baseline quantitative measures for trustworthy characteristics.
• Delimit and characterize baseline operation values and states.
• Utilize qualitative approaches to augment and complement quantitative baseline
measures, in close coordination with impact assessment, human factors and socio-
technical AI actors.
• Monitor and assess measurements as part of continual improvement to identify
potential system adjustments or modifications
• Perform and document sensitivity analysis to characterize actual and expected variance
in performance after applying system or procedural updates.
• Document decisions related to the sensitivity analysis and record expected influence on
system performance and identified risks.

Transparency & Documentation

Organizations can document the following


• To what extent are the model outputs consistent with the entity’s values and principles
to foster public trust and equity?
• How were sensitive variables (e.g., demographic and socioeconomic categories) that
may be subject to regulatory compliance specifically selected or not selected for
modeling purposes?
• Did your organization implement a risk management system to address risks involved
in deploying the identified AI solution (e.g. personnel risk or changes to commercial
objectives)?
• How will the accountable human(s) address changes in accuracy and precision due to
either an adversary’s attempts to disrupt the AI or unrelated changes in the
operational/business environment?
• How will user and peer engagement be integrated into the model development process
and periodic performance review once deployed?

AI Transparency Resources
• GAO-21-519SP - Artificial Intelligence: An Accountability Framework for Federal
Agencies & Other Entities.
• Artificial Intelligence Ethics Framework For The Intelligence Community.

References
Batya Friedman, and David G. Hendry. Value Sensitive Design: Shaping Technology with
Moral Imagination. Cambridge, MA: The MIT Press, 2019.

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Batya Friedman, David G. Hendry, and Alan Borning. “A Survey of Value Sensitive Design
Methods.” Foundations and Trends in Human-Computer Interaction 11, no. 2 (November
22, 2017): 63–125.

Steven Umbrello, and Ibo van de Poel. “Mapping Value Sensitive Design onto AI for Social
Good Principles.” AI and Ethics 1, no. 3 (February 1, 2021): 283–96.

Karen Boyd. “Designing Up with Value-Sensitive Design: Building a Field Guide for Ethical
ML Development.” FAccT '22: 2022 ACM Conference on Fairness, Accountability, and
Transparency, June 20, 2022, 2069–82.

Janet Davis and Lisa P. Nathan. “Value Sensitive Design: Applications, Adaptations, and
Critiques.” In Handbook of Ethics, Values, and Technological Design, edited by Jeroen van
den Hoven, Pieter E. Vermaas, and Ibo van de Poel, January 1, 2015, 11–40.

Ben Shneiderman. Human-Centered AI. Oxford: Oxford University Press, 2022.

Shneiderman, Ben. “Human-Centered AI.” Issues in Science and Technology 37, no. 2
(2021): 56–61.

Shneiderman, Ben. “Tutorial: Human-Centered AI: Reliable, Safe and Trustworthy.” IUI '21
Companion: 26th International Conference on Intelligent User Interfaces - Companion, April
14, 2021, 7–8.

George Margetis, Stavroula Ntoa, Margherita Antona, and Constantine Stephanidis. “Human-
Centered Design of Artificial Intelligence.” In Handbook of Human Factors and Ergonomics,
edited by Gavriel Salvendy and Waldemar Karwowski, 5th ed., 1085–1106. John Wiley &
Sons, 2021.

Caitlin Thompson. “Who's Homeless Enough for Housing? In San Francisco, an Algorithm
Decides.” Coda, September 21, 2021.

John Zerilli, Alistair Knott, James Maclaurin, and Colin Gavaghan. “Algorithmic Decision-
Making and the Control Problem.” Minds and Machines 29, no. 4 (December 11, 2019): 555–
78.

Fry, Hannah. Hello World: Being Human in the Age of Algorithms. New York: W.W. Norton &
Company, 2018.

Sasha Costanza-Chock. Design Justice: Community-Led Practices to Build the Worlds We


Need. Cambridge: The MIT Press, 2020.

David G. Robinson. Voices in the Code: A Story About People, Their Values, and the
Algorithm They Made. New York: Russell Sage Foundation, 2022.

Diane Hart, Gabi Diercks-O'Brien, and Adrian Powell. “Exploring Stakeholder Engagement in
Impact Evaluation Planning in Educational Development Work.” Evaluation 15, no. 3
(2009): 285–306.

136 of 137
Asit Bhattacharyya and Lorne Cummings. “Measuring Corporate Environmental
Performance – Stakeholder Engagement Evaluation.” Business Strategy and the
Environment 24, no. 5 (2013): 309–25.

Hendricks, Sharief, Nailah Conrad, Tania S. Douglas, and Tinashe Mutsvangwa. “A Modified
Stakeholder Participation Assessment Framework for Design Thinking in Health
Innovation.” Healthcare 6, no. 3 (September 2018): 191–96.

Fernando Delgado, Stephen Yang, Michael Madaio, and Qian Yang. "Stakeholder
Participation in AI: Beyond 'Add Diverse Stakeholders and Stir.'" arXiv preprint, submitted
November 1, 2021.

Emanuel Moss, Elizabeth Watkins, Ranjit Singh, Madeleine Clare Elish, and Jacob Metcalf.
“Assembling Accountability: Algorithmic Impact Assessment for the Public Interest.” SSRN,
July 8, 2021.

Alexandra Reeve Givens, and Meredith Ringel Morris. “Centering Disability Perspectives in
Algorithmic Fairness, Accountability, & Transparency.” FAT* '20: Proceedings of the 2020
Conference on Fairness, Accountability, and Transparency, January 27, 2020, 684-84.

137 of 137

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