Reflection on the proof of concept

Part 8/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

 

For this EPSRC impact acceleration project conducted over a period of three months, we have implemented the Loan Decision scenario, instrumented the pipeline so that it produces provenance, categorised explanations according to their audience and their purpose, built an explanation-generation prototype, and wrapped the whole system in an online demonstrator.

This work aimed to demonstrate that provenance, defined as a record that describes the people, institutions, entities, and activities involved in producing, influencing, or delivering a decision, is a solid foundation for generating explanations.

We are delighted to release a report summarising all this work.

https://explain.openprovenance.org/report/

Some lessons can be drawn from this piece of work.

 

1. General considerations

 

Given the short duration of the project, there are inevitably some limitations. First, we discuss some general considerations.

  • First, we designed this prototype for one application scenario, for one machine learning pipeline, for one specific regulatory framework (GDPR), and for a subset of requirements from this framework. It is our intent to generalise the approach to other scenarios, regulations and requirements.
  • Second, the approach is predicated on finding specific mark-ups in the provenance, to be able to construct the relevant explanations. Besides the above generalisation, there is also a clear need to document such mark-ups, so that data controllers can adapt their system to produce suitably annotated provenance. It has to be understood by data controllers that a failure to generate provenance with the right mark-ups will result in the system’s inability  of constructing some explanations.
  • Third, adequate tools need to be provided to assist data controllers in producing the right provenance information, and in checking that it addresses data protection (or others) requirements they are under the obligation to meet.
  • Fourth, explanations can and should be refined to fully meet their purposes. Extensive requirement capturing and user studies will help validate these.
  • Fifth, it is our belief that explanations could be viewed as more than just one paragraph communicated to the data subject in a single request-response interaction. We envisage explanations potentially as part of a dialogue between the system and its targeted recipients. A mechanism to design such an explanation service would, therefore, be required.
  • Finally, some aspects of the decision-making pipeline are currently not explained. It is particularly the case of the machine learning algorithm itself, which remains a black-box: the algorithm was used to create a model, and the model was used to classify some input data. Both the model creation and classification are modelled by activities in the provenance. If some libraries are able to generate further provenance, this, in turn, can be turned into explanations.

 

2.    Refining Explanations

 

  • We generate different explanations for automated and human decisions. Something to investigate is how meaningful the human involvement is. How much is added by the human on top of the automated recommendation they proceed? Can the meaningfulness be determined automatically? Which semantic mark-up in the provenance would help with this task?
  • We were able to demonstrate that some loan application characteristics (or elements of third-party data such as credit reference) were not used by the decision-making pipeline. This information, while certainly useful, is looking at “syntactic usage”: some data may have been passed to the pipeline, but may or may not have been effectively used to reach the decision. In other words, the data may or may not have had an influence on the final decision. However, such information can only be surfaced if we gain a better understanding of the black box.
  • Counter-factual explanations. We have demonstrated that it is possible to construct simple counter-factual explanations out of provenance. By simply considering alternate loan applications in a counter-factual world (e.g. loan for a different purpose, for a different amount, for a data subject with different profile), and applying the pipeline, we obtain counter-factual decisions. By marking the original loan application and associated decision, as well as alternate applications, we were able to construct an example of counter-factual explanation. This approach needs to be generalised and the nature of explanations that can be supported needs to be further studied.

 

3.  Where next?

 

This limited proof-of-concept exercise is only the start of a journey. With the new EPSRC-funded PLEAD: Provenance-driven and Legally-grounded Explanations for Automated Decisions, we are about to embark in novel research to address some of above concerns.  More posts on this topic will follow.

PLEAD Project: https://plead-project.org/

Full report for this project: https://explain.openprovenance.org/report/

Demonstrator:  https://explain.openprovenance.org/

 

 

Explanations for Automated Decisions from Provenance – A Demonstrator

Part 7/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

 

In the previous post, we presented our approach to generating explanations from provenance and provided an illustration for one type of explanations. Follow the same approach, we have implemented an explanation for most of the categories we identified in the loan decision scenario. The implementation is deployed online at https://explain.openprovenance.org to demonstrate the explanations we generate from the provenance of a loan decision.

 

demonstrator-1

 

1. Simulate a Loan Application

 

The simulator supports the loan decision pipeline scenario, in which you can play the role of a borrower applying for a loan.

 

demonstrator-2

First, you can simulate a new loan application – filling in a loan application, whose data will be randomly picked from our dataset.

 

demonstrator-3

 

At this point, you can submit the application to get a loan decision.

 

demonstrator-4

 

The provenance of a decision is recorded, detailing the processes taking place to arrive at the decision. It can be accessed via the Provenance button.

 

2.  Checking out the explanations

 

Below the loan decision, you will find a list of questions that an applicant may inquire about its various aspects.

 

demonstrator-5

 

For instance, they may ask whether the decision was solely automated. The Automation tab will provide the answer, which is generated from the provenance data of the decision. Below each explanation, we provide its legal and business contexts that call for the explanation.

 

demonstrator-6

 

Do try out the demonstrator and let us know what you think. At the bottom of each page, there is a yellow question mark; clicking on it will allow you to send us quick feedback, or any suggestion, on the page that you are seeing.

 

3.  Coming next

 

This is the seventh in our 8-part blog series on explanations for automated decisions from provenance. In the last post, we will summarise our short journey exploring this novel and exciting application of provenance and discuss where we want to go next.

 

 

Constructing explanations from provenance

Part 6/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

In this sixth blog post on provenance-based explanations, we look at the mechanism we use to construct explanations from provenance. First, we summarise the overall approach, and then, we look at the details.

1. Overview

 

Figure 1 illustrates our approach to generating explanations. We will discuss it, point by point.

explanations

Figure 1: Provenance Based Explanation Generation

 

In the introductory blog post, we provided the definition of provenance as “a record that describes the people, institutions, entities, and activities involved in producing, influencing, or delivering a pied of data or a thing in the world”. Our focus here is the provenance of an AI-based decision (see 1, Figure 1).

It is our view that such a provenance record is an excellent starting point to construct an explanation specific to a decision, helping a data subject understand it and take action in response to it, appropriate for the context (see 2). Thus, we are assuming that the AI based application has been instrumented in order to log provenance (see 3). To this end, we have been developing various techniques by which code can be instrumented, some libraries have been instrumented, and even provenance can be reconstructed from logged data.

In this project, we instrumented a loan decision pipeline to record the full provenance of a loan decision in the scenario.

The result is a provenance graph (see 4) providing full details of the inputs and processing leading to a decision, including data items, processes, agents that have influenced decisions. In long-running applications, and in applications processing a vast amount of data, potentially this provenance can become very large.

This full record in itself is not conducive to construct an explanation directly, since it may contain too many details that a data subject may find irrelevant, tedious, or overwhelming.  Instead, the provenance needs to be processed (see 5) to produce relevant information nuggets in support a specific explanation’s purpose: this may involve summarisation and analytics, to extract the essence of provenance. The result is what we refer to as a provenance summary (see 6).

The provenance summary is the input to a generation component (see 7), converting relevant summary information into an explanation, which in our case would be textual. Alternatively, or additionally, the same extracted information could be represented in a graphical way to further aid its consumption.  The outcome is an explanation which could be targeted to the data subject (and would typically refer to the data subject and their data, using “you” or “your application”) or to the data controller (and then would typically use “the borrower” or “the borrower’s application” instead).

2.  Illustration

 

In this section, we illustrate the approach with the explanation Time Relevance from the loan scenario.

A question a data subject may want to ask is “How timely relevant is the data used for assessing my loan?” so they can check if the latest data are being used (since they may believe that their circumstances have recently changed in their favour).

This question can be addressed by extracting all data items that have affected a decision. In the instance of a loan decision, they consist of 3 items: the loan application made by the borrower, and two credit references obtained from two distinct external credit referencing agencies.  It is these that are of interest to the data subject, as they want to ensure that they are the most recent.

A suitable query over the provenance of the decision can be designed and executed to extract the following subgraph, out of which the relevant information can be found to construct the explanation.  In the graph shown below, at the bottom, we find the decision (yellow ellipsis), and three influencing entities from which it was derived: the loan application, a fico score and a credit history.  The latter two are provided by external agencies (fico) and (credit_agency), represented as orange pentagons.

936

Figure 2: Query Result for “Time Relevance” explanation

 

Out of the extracted provenance subgraph, one can then construct the following explanation.  It explicitly lists the external credit referencing agencies, the credit references they provided, and the time at which such credit references were obtained.

The external data sources were the borrower FICO score (fico_score/29) provided by the credit referencing agency (fico) at <2019-06-15T20:46:39.921182> and the borrower credit reference (credit_history/29) provided by the credit referencing agency (credit_agency) at <2019-06-20T12:43:31.114156>.

The explanation can then further be enriched by providing contact details for these external agencies.  Taking our approach of “Explanations as Detective Controls”, the explanation allows as data subject to detect if external information is timely; the explanation is actionable, as data subjects can use the contact details to approach these agencies, query the credit reference, and potentially have it fixed.

A standard such as PROV allows multiple organisations to share provenance information in an interoperable manner.   In this simulated example, the provenance is created by the loan company, based on the processes it follows.  If the loan company and credit referencing agencies inter-operate properly, we can envisage that not only they exchange credit reference but also (some of) the provenance of these credit references. Credit reference agencies themselves rely on external organisations to compile these references.  All that information can be transformed into actionable information for the data subject

3.  Coming Next

 

In the next blog posts, we present the demonstrators for the loan application and associated explanations, computed on the fly, using the provenance it generates.

Tracking Provenance in a Decision Pipeline

Part 5/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

In the first post of this series, we argued that the provenance of automated decisions is a valuable source of data from which explanations about those decisions can be generated. In order to demonstrate that capability, we first need to record the provenance of such decisions in our hypothetical loan scenario.

As the loan decision pipeline was implemented in Python, we use the PROV Python package to make provenance assertions that are compliant to the PROV recommendations by the World Wide Web Consortium. In brief, the PROV Data Model defines three basic concepts, Entity, Activity and Agent (see Figure below) and various relations between them. For instance, an entity can be used by an activity to generate some new entity; the activity itself may be influenced in some ways by agents.

PROV concept Description Examples
prov-concept-entity A thing, either physical, digital or conceptual, whose provenance we want to describe piece of information, decision, document, plan, dataset, trained machine learning model
prov-concept-activity Occurs over a period of time and acts upon or with entities actions such as planning, monitoring, approving, training, classifying
prov-concept-agent Bears some form of responsibility for an activity taking place, for the existence of an entity, or for another agent’s activity person, machine, service, system, organisation, collective

In the following sections, we present the recorded provenance of a loan decision step-by-step, from the loan application made by a borrower to its classification by the machine learning pipeline and the final decision, either automated or made by a loan officer.

1   Provenance of Input Data

The first piece of inputs to the pipeline is the loan application (loan:applications/35) made by an applicant (see entity loan:applicants/35 in Figure below). The application entity contains the data provided by the applicant in the application form (shown in the white box linked to the entity by a dotted line). In addition, the Loan Company obtains the applicant’s credit history (loan:credit_history/35) and credit score (loan:fico_score/35) from third-party organisations (loan:credit_agency and loan:fico, respectively). Each of the input entities is attributed to the corresponding agent via an attribution relation.

inputs

2   Classification of a Loan Application

The input data are then transformed into a set of loan features, modelled as an entity (py:loan_features/35), that is suitable for processing by the machine learning pipeline. The provenance of the loan features entity is explicitly asserted by the derivation relations linking it to the input entities from which it was produced.

loan_features

A computer (ex:machine/8e7425f366a0) classifies the loan features using the pipeline (loan:pipeline/1) and produces a recommendation (ex:recommendation/35) on the loan application. It does so, however, on behalf of the Loan Company (loan:institution). The process of classification is modelled as an activity (ex:classify_loans/35), which has a start time and an end time; it uses the loan features as inputs and generates the recommendation as the output.

classification

3 Making a Loan Decision

Let us consider the case in which the pipeline predicts that the probability of charge-off is very low (3.5%) and, hence, an automated approval decision is generated directly from the recommendation from the pipeline. The decision is attributed to the computer running the pipeline; however, the chain of responsibility is made clear: the computer produces the decision on behalf of the Loan Company.

decision_automated

In another case, the probability of charge-off is on the borderline (25.4%), the automated recommendation is escalated to a review carried out by a loan officer (loan:staff/112). The loan decision is now attributed not to the computer but to the officer, who also acts on behalf of the Loan Company. Compared to the previous, automated case, the provenance in this case shows that the review activity takes into account the loan application, the credit history, and the credit score of the applicant in addition to the automated recommendation produced by the pipeline.

decision_human

4 Discussion

For the sake of brevity, we present the provenance of a decision here in small, digestible snippets. The full provenance of a decision is recorded as a single directed graph allowing one to trace from the provenance back to the input data and to identify the responsibility for each of the activities found along the way.

Each of the entities is categorised by types with one or more prov:type attributes. Most types are application-specific such as ln:LoanApplication, ln:FICOScore, and ln:CreditOfficer. In addition, we tag certain entities with types that will be useful for identifying relevant data in support explanation generation: pl:Controlled, pl:HumanLedActivity, prov:SoftwareAgent, prov:Person and so on. In the next post, we discuss the technical approach to generate explanations from the recorded provenance.

Explanations for Automated Decisions – Examples

Part 4/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

In the previous blog post, we introduced the loan scenario, in which a borrower submits a loan application and receives a decision on the application from an automated decision pipeline. In a workshop with colleagues at the Information Commissioner’s Office, we brainstormed on various questions that a data subject may have on such a decision. We paid particular attention to the rights granted to data subjects by the GDPR on such circumstances and, hence, questions of which answers would help the subjects exercise those rights. In addition, we also discussed questions and answers, or explanations, on aspects of the loan decision pipeline that would help data controllers to meet their obligations or demonstrate compliance with their obligations. These explanations would, thus, be particularly useful to establish data protection by design and by default.

The types of explanations thereby generated can be classified into two categories depending upon whose concerns they address, as illustrated below.

Individual Concerns Organisational Concerns
Automation Performance
Data Inclusion Responsibility
Data Exclusion Process
Data Source Systemic Discrimination or Bias
Data Accuracy Ongoing Monitoring
Data Currency
Profile-related Fairness
Discrimination-related Fairness

In this post, we expand upon two of the foregoing explanations. In each of them, we identify the target audience of the explanation, the corresponding questions they may have, the rationale for an organisation to provide such an explanation, and example explanations in the context of the loan decision scenario. The descriptions of all the categories will be available in our final report to be made available with the last post in this series.

1       Automation

Audience Data subjects
Questions Has the loan decision been reached solely via automated means?
Description Whether a decision made solely by automated means without any meaningful human involvement.
Rationale This explanation helps determine whether GDPR Article 22 is applicable and thereby the prohibition applies: “The data subject shall have the right not to be subject to a decision based solely on automated processing…” It is therefore relevant for demonstrating compliance with Article 5(1)(a) (fairness principle) and Article 5(2) (principle of accountability).

This explanation should also help understand when best practice as unfolded in Recital 71 is met, e.g. to determine whether both child data and solely automated means have been used.

This explanation could also help determine whether the information provided to the data subject as per Article 13, 14 and 15 is adequate.

Examples The automated recommendation was reviewed by a credit officer (staff/112) whose decision was based on your application (applications/34), the automated recommendation (recommendation/34) itself, a credit reference (credit_history/34) and a fico score (fico_score/34).</code>
The loan application was automatically approved based on a combination of the borrower loan application and third-party data: the borrower credit reference and the borrower FICO score.

2       Responsibility

Audience Data controller, Regulator
Questions Who were responsible for the final decision pipeline?

Who set the threshold value for automated decisions?

Who decided how the data was selected?

Who approved the pipeline for deployment?

Description As part of their own governance and to support accountability, organisations must keep track of who did what and when in their internal processes.
Rationale This explanation would help determine whether the data is processed fairly and transparently (Article 5(1)(a)) (although this would not lead to a complete fairness assessment). Ultimately its implementation would be useful for accountability purposes.
Examples Responsibilities for the AI pipeline were that data engineer (staff/259) selected file (loans_filtered.xz), that data engineer (staff/259) split file (loans_train.xz), that manager (staff/37) approved the company pipeline (pipeline/1) and that data engineer (staff/259) fit data for the company pipeline (1558649326/5011959424).

3       Coming next

This is the fourth post in a series of blog posts on Explanations for AI-based decisions. In the next post, we describe how the provenance of a loan decision is modelled and recorded to support the generation of explanations for such a decision. Future work will then involve determining the level of usefulness of meaningfulness reached by these explanations.

A Scenario of Automated Decision-Making

Part 3/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

Credit applications nowadays are typically assessed by automated systems and often approved or rejected within seconds, without human intervention. In this project, we imagine a loan scenario that allows us to simulate such an automated decision pipeline with the aim to explore potential questions one may ask about its decisions.

1. The Loan Assessment Scenario

 

Loan Company is a credit institution that offers short-term unsecured loans to borrowers. In order to minimise loss from charge-off, i.e. when a loan is unlikely to be repaid by the borrower, the institution developed a machine-learning pipeline that predicts the probability of a charge-off from a loan application. Based on this probability, a recommendation is made on whether the application should be approved or rejected.

The pipeline was trained and tested on the company’s past loan performance data and was shown to perform reasonably well. It was approved for deployment to access all incoming loan applications and is enabled to make automatic decisions in clear-cut cases without the attention of a loan officer:

  • If the probability of charge-off is higher than 50%, the loan application is automatically rejected
  • If the probability is less than 25%, it is automatically approved.
  • A loan officer has to examine the remaining cases (i.e. where the probability is between 25% and 50%) and make the final decision.

LoanDecisionPipeline

2. Building the Automated Decision Pipeline

 

To add some realism to the loan scenario, we use a real-world loan performance dataset originally published by LendingClub to build the decision pipeline. The dataset went through typical machine learning analysis, filtering, and transformations:

  • Data filtering and selection:
    1. Only loans that have finished, either as fully paid or charged off, are retained.
    2. Loan features (i.e. data fields) with significant missing data (i.e. over 30%) or that are not available before a loan is approved are removed.
  • Data preparation and transformation:
    1. Remove loan features that are clearly not useful as predictors for charge-off:
      1. All values are unique or too many different values
      2. Features that are already included in another (duplication)
    2. Convert feature values to those suitable for machine learning
      1. Loan status (fully paid/charged off) to 0/1 labels
      2. Replace categorical features with dummy labels (0/1) for each of their categories
  • Split data into train and test sets according to the loan date: 90% and 10%
  • Create a machine learning pipeline with Scikit-learn to combine imputation and decision tree classification
  • Train the pipeline with the training dataset (90%)
  • Validate its accuracy with the test set (10%)

BuildingLoanDecisionPipeline

 

3. Some potential questions

 

In the loan scenario, in order to borrow money from Loan Company, borrowers would need to submit applications that contain their personal information such as their addresses, their income levels, whether they are homeowners, and so on. Loan Company does not just rely on those but, in a typical case, would also routinely obtain credit references on the borrowers to check their creditworthiness.

As a data subject whose personal data is being processed and profiled by Loan Company in a highly automated manner, a borrower has certain legal rights, e.g. the rights to be informed about the modalities of the processing and the logic involved, to access his/her data, to rectify inaccurate data and potentially (at least in instances in which the processing is purely automated) to request human intervention and to challenge a decision (we assume GDPR Recital 71 should inform the interpretation of Article 22). However, in order to be able to decide whether to exercise these rights, the borrower should be put in a situation in which he can obtain meaningful insights into the processing activities and for instance receive answers to the following questions:

  • Was the loan decision they receive made by a human or an automated process?
  • What types of data were used to assess my loan application?
  • Where did those data come from?
  • Are they all accurate?

The explanations thereby provided can be thus be conceived as detective controls or safeguards giving data subjects the opportunity to check whether a remedy is applicable.

4. Coming next

 

In the following blog post, we identify the different types of explanations and argue why they are useful to both data subjects and data controllers.

 

Explanations as detective controls

Part 2/8: A blog post series by Dong Huynh, Sophie Stalla-Bourdillon and Luc Moreau

Automated decision-making has been and continues to be the subject of attention since the adoption of the General Data Protection Regulation in 2016. Academics from different disciplines have discussed at length the domain and effect of a right to explanation, exploring in particular two routes to generate explanations. L. Edwards and M. Veale explain that at a high level, explanations can be grouped into two classes: “model-centric explanations (MCEs) and subject-centric explanations (SCEs).” They observe that explanations might not be particularly useful to vindicate data subject rights but could prove useful to increase the level of trust in Machine Learning (ML) models or as pedagogical tools. S. Wachter et al. highlight the benefits of counterfactual explanations, which make it possible to generate explanations without opening algorithmic black boxes.

In this project on constructing explanations from provenance data, we build upon A. Selbst and J. Powles’ approach who argue that “a flexible approach, guided by… functional requirements…, can best effectuate [the right to explanation] while preserving the ability of technologists to innovate in ML and AI.”

1. Explanations as detective controls

 

A. Selbst and J. Powles make the point that information is meaningful where it serves a “functional” purpose, i.e. when it has “instrumental value” such as the facilitation of a data subject’s right to contest a decision. We broaden the claim and argue that explanations have the potential to serve all “data protection goals,” to use the expression at the core of the approach of the German Supervisory Authorities and expanded upon in the Standard Data Protection Model (SDM).

We, therefore, start from the assumption that information and, in particular, provenance-related information, is useful or meaningful each time it helps data controllers to demonstrate compliance with Article 5 data protection principles and other related-data protection requirements or each time it helps data subjects to exercise their rights (the list of rights should go beyond Article 22, i.e. the right not to be subject to a decision based solely on automated processing).

Explanations are, therefore, conceived as detective controls (measures facilitating the detection of potential compliance issues or of opportunities to exercise a right), which can benefit both data controllers and data subjects and which should be at the core of any data protection by design strategy.  In fact, to be able to bake data protection principles within systems as early as possible and meet the requirement of data protection by design introduced by the GDPR in its Article 25, data controllers should embed a mix of preventive, directive, detective and corrective controls (i.e. organisational or technical measures aimed at implementing data protection principles as early as possible). Detective controls are important to meet the principle of accountability, which requires that the data controller be in a position to demonstrate compliance and in particular compliance with the principles of purpose limitation, data minimisation, accuracy, fairness, transparency… Detective controls are also important to “integrate the necessary safeguards into the processing in order to … protect the rights of data subjects” (see Article 25).

Let’s take an example. In the context of a loan decision, an explanation generating information relating to the freshness of the data could take the following form:

The data sources were a credit reference (credit_history/128350251) provided by the credit agency (credit_agency) at <2019-01-10T14:10:16> and a fico score (fico_score/128350251) provided by the credit agency (fico) at <2019-03-10T11:00:00>.

Such an explanation would thus make it possible for the data subject to assess whether accurate data has been used or not and eventually react and ask for correction.

From a data subject’s standpoint (the same is also true from a data controller’s standpoint) both the data query itself and the resulting explanation are therefore important to detect whether accurate data has been processed. They are both key components of an effective detective control or safeguard. Conceiving explanations as detective controls makes it possible to go beyond the debate whether the GDPR introduces a right to explanation to the benefits of data subjects, and to give data controllers an incentive to consider introducing explanatory methods each time they are using models to support decision-making.

Broadly defined, explanations can thus be described as the details or reasons provided to make an automated decision clearer or easier to understand. For our purposes, a decision can be either partially or fully automated; and in many cases, it is likely that a human will be included in the loop.

2. Linking explanations to goals and audience in context

 

Linking explanations to functional purposes or data protection goals is critical because, contrary to what is often assumed, explanations can be multiform. In other words, a wide variety of explanations can be generated and their usefulness or meaningfulness is intrinsically dependent upon the specific goal they pursue. Counterfactual explanations, which usually take the form: “If X was different, Y would have been different/the same,” are thus only one form of subject-centric explanations, which are not useful or meaningful in all circumstances.

Our initial list of goals, which will be refined over time, comprises: transparency, accuracy, data minimisation, fairness (with three sub-goals: automation, profile-related fairness, discrimination-related fairness), intervenability (with four sub-goals access, rectification, portability, contestability of purely automated decision-making), accountability (with four sub-goals performance, responsibility, process, on-going monitoring).

What is more, it is also important to understand who the recipient of the information is and what his or her expectations are. In other words, it is important to precisely identify the needs of what we call the audience of the explanations in addition to its goal.

By precisely determining the content of the data controller’s obligations or the effect of the data subject’s rights and thereby deriving what we call the rationale for the explanation, it should be possible to assess whether the explanation generated has reached an acceptable level of usefulness or meaningfulness. In order to do so, analysing data controller obligations and data subject rights in context is particularly helpful. Hence our attempt to build a prototype for a particular scenario in which an application for a loan is submitted to the data controller.

3. Coming Next

 

This is the second post in a series of blog posts. In the next post, we introduce a fictitious AI-based automated decision scenario, a loan application, and present kinds of explanations that are relevant to both data subjects and data controllers.