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Mar 11

Regulatory Compliance through Doc2Doc Information Retrieval: A case study in EU/UK legislation where text similarity has limitations

Major scandals in corporate history have urged the need for regulatory compliance, where organizations need to ensure that their controls (processes) comply with relevant laws, regulations, and policies. However, keeping track of the constantly changing legislation is difficult, thus organizations are increasingly adopting Regulatory Technology (RegTech) to facilitate the process. To this end, we introduce regulatory information retrieval (REG-IR), an application of document-to-document information retrieval (DOC2DOC IR), where the query is an entire document making the task more challenging than traditional IR where the queries are short. Furthermore, we compile and release two datasets based on the relationships between EU directives and UK legislation. We experiment on these datasets using a typical two-step pipeline approach comprising a pre-fetcher and a neural re-ranker. Experimenting with various pre-fetchers from BM25 to k nearest neighbors over representations from several BERT models, we show that fine-tuning a BERT model on an in-domain classification task produces the best representations for IR. We also show that neural re-rankers under-perform due to contradicting supervision, i.e., similar query-document pairs with opposite labels. Thus, they are biased towards the pre-fetcher's score. Interestingly, applying a date filter further improves the performance, showcasing the importance of the time dimension.

Corrective or Backfire: Characterizing and Predicting User Response to Social Correction

Online misinformation poses a global risk with harmful implications for society. Ordinary social media users are known to actively reply to misinformation posts with counter-misinformation messages, which is shown to be effective in containing the spread of misinformation. Such a practice is defined as "social correction". Nevertheless, it remains unknown how users respond to social correction in real-world scenarios, especially, will it have a corrective or backfire effect on users. Investigating this research question is pivotal for developing and refining strategies that maximize the efficacy of social correction initiatives. To fill this gap, we conduct an in-depth study to characterize and predict the user response to social correction in a data-driven manner through the lens of X (Formerly Twitter), where the user response is instantiated as the reply that is written toward a counter-misinformation message. Particularly, we first create a novel dataset with 55, 549 triples of misinformation tweets, counter-misinformation replies, and responses to counter-misinformation replies, and then curate a taxonomy to illustrate different kinds of user responses. Next, fine-grained statistical analysis of reply linguistic and engagement features as well as repliers' user attributes is conducted to illustrate the characteristics that are significant in determining whether a reply will have a corrective or backfire effect. Finally, we build a user response prediction model to identify whether a social correction will be corrective, neutral, or have a backfire effect, which achieves a promising F1 score of 0.816. Our work enables stakeholders to monitor and predict user responses effectively, thus guiding the use of social correction to maximize their corrective impact and minimize backfire effects. The code and data is accessible on https://github.com/claws-lab/response-to-social-correction.

Compliance Cards: Computational Artifacts for Automated AI Regulation Compliance

As the artificial intelligence (AI) supply chain grows more complex, AI systems and models are increasingly likely to incorporate externally-sourced ingredients such as datasets and other models. In such cases, determining whether or not an AI system or model complies with the EU AI Act will require gathering compliance-related metadata about both the AI system or model at-large as well as those externally-supplied ingredients. There must then be an analysis that looks across all of this metadata to render a prediction about the compliance of the overall AI system or model. Up until now, this process has not been automated. Thus, it has not been possible to make real-time compliance determinations in scenarios where doing so would be advantageous, such as the iterative workflows of today's AI developers, search and acquisition of AI ingredients on communities like Hugging Face, federated and continuous learning, and more. To address this shortcoming, we introduce a highly automated system for AI Act compliance analysis. This system has two key elements. First is an interlocking set of computational artifacts that capture compliance-related metadata about both: (1) the AI system or model at-large; (2) any constituent ingredients such as datasets and models. Second is an automated analysis algorithm that operates across those computational artifacts to render a run-time prediction about whether or not the overall AI system or model complies with the AI Act. Working together, these elements promise to enhance and accelerate AI Act compliance assessments.

SimpleSafetyTests: a Test Suite for Identifying Critical Safety Risks in Large Language Models

The past year has seen rapid acceleration in the development of large language models (LLMs). However, without proper steering and safeguards, LLMs will readily follow malicious instructions, provide unsafe advice, and generate toxic content. We introduce SimpleSafetyTests (SST) as a new test suite for rapidly and systematically identifying such critical safety risks. The test suite comprises 100 test prompts across five harm areas that LLMs, for the vast majority of applications, should refuse to comply with. We test 11 open-access and open-source LLMs and four closed-source LLMs, and find critical safety weaknesses. While some of the models do not give a single unsafe response, most give unsafe responses to more than 20% of the prompts, with over 50% unsafe responses in the extreme. Prepending a safety-emphasising system prompt substantially reduces the occurrence of unsafe responses, but does not completely stop them from happening. Trained annotators labelled every model response to SST (n = 3,000). We use these annotations to evaluate five AI safety filters (which assess whether a models' response is unsafe given a prompt) as a way of automatically evaluating models' performance on SST. The filters' performance varies considerably. There are also differences across the five harm areas, and on the unsafe versus safe responses. The widely-used Perspective API has 72% accuracy and a newly-created zero-shot prompt to OpenAI's GPT-4 performs best with 89% accuracy. Content Warning: This paper contains prompts and responses that relate to child abuse, suicide, self-harm and eating disorders, scams and fraud, illegal items, and physical harm.

CONFLARE: CONFormal LArge language model REtrieval

Retrieval-augmented generation (RAG) frameworks enable large language models (LLMs) to retrieve relevant information from a knowledge base and incorporate it into the context for generating responses. This mitigates hallucinations and allows for the updating of knowledge without retraining the LLM. However, RAG does not guarantee valid responses if retrieval fails to identify the necessary information as the context for response generation. Also, if there is contradictory content, the RAG response will likely reflect only one of the two possible responses. Therefore, quantifying uncertainty in the retrieval process is crucial for ensuring RAG trustworthiness. In this report, we introduce a four-step framework for applying conformal prediction to quantify retrieval uncertainty in RAG frameworks. First, a calibration set of questions answerable from the knowledge base is constructed. Each question's embedding is compared against document embeddings to identify the most relevant document chunks containing the answer and record their similarity scores. Given a user-specified error rate ({\alpha}), these similarity scores are then analyzed to determine a similarity score cutoff threshold. During inference, all chunks with similarity exceeding this threshold are retrieved to provide context to the LLM, ensuring the true answer is captured in the context with a (1-{\alpha}) confidence level. We provide a Python package that enables users to implement the entire workflow proposed in our work, only using LLMs and without human intervention.

CODE-ACCORD: A Corpus of Building Regulatory Data for Rule Generation towards Automatic Compliance Checking

Automatic Compliance Checking (ACC) within the Architecture, Engineering, and Construction (AEC) sector necessitates automating the interpretation of building regulations to achieve its full potential. However, extracting information from textual rules to convert them to a machine-readable format has been a challenge due to the complexities associated with natural language and the limited resources that can support advanced machine-learning techniques. To address this challenge, we introduce CODE-ACCORD, a unique dataset compiled under the EU Horizon ACCORD project. CODE-ACCORD comprises 862 self-contained sentences extracted from the building regulations of England and Finland. Aligned with our core objective of facilitating information extraction from text for machine-readable rule generation, each sentence was annotated with entities and relations. Entities represent specific components such as "window" and "smoke detectors", while relations denote semantic associations between these entities, collectively capturing the conveyed ideas in natural language. We manually annotated all the sentences using a group of 12 annotators. Each sentence underwent annotations by multiple annotators and subsequently careful data curation to finalise annotations, ensuring their accuracy and reliability, thereby establishing the dataset as a solid ground truth. CODE-ACCORD offers a rich resource for diverse machine learning and natural language processing (NLP) related tasks in ACC, including text classification, entity recognition and relation extraction. To the best of our knowledge, this is the first entity and relation-annotated dataset in compliance checking, which is also publicly available.

Who Audits the Auditors? Recommendations from a field scan of the algorithmic auditing ecosystem

AI audits are an increasingly popular mechanism for algorithmic accountability; however, they remain poorly defined. Without a clear understanding of audit practices, let alone widely used standards or regulatory guidance, claims that an AI product or system has been audited, whether by first-, second-, or third-party auditors, are difficult to verify and may exacerbate, rather than mitigate, bias and harm. To address this knowledge gap, we provide the first comprehensive field scan of the AI audit ecosystem. We share a catalog of individuals (N=438) and organizations (N=189) who engage in algorithmic audits or whose work is directly relevant to algorithmic audits; conduct an anonymous survey of the group (N=152); and interview industry leaders (N=10). We identify emerging best practices as well as methods and tools that are becoming commonplace, and enumerate common barriers to leveraging algorithmic audits as effective accountability mechanisms. We outline policy recommendations to improve the quality and impact of these audits, and highlight proposals with wide support from algorithmic auditors as well as areas of debate. Our recommendations have implications for lawmakers, regulators, internal company policymakers, and standards-setting bodies, as well as for auditors. They are: 1) require the owners and operators of AI systems to engage in independent algorithmic audits against clearly defined standards; 2) notify individuals when they are subject to algorithmic decision-making systems; 3) mandate disclosure of key components of audit findings for peer review; 4) consider real-world harm in the audit process, including through standardized harm incident reporting and response mechanisms; 5) directly involve the stakeholders most likely to be harmed by AI systems in the algorithmic audit process; and 6) formalize evaluation and, potentially, accreditation of algorithmic auditors.

Consent in Crisis: The Rapid Decline of the AI Data Commons

General-purpose artificial intelligence (AI) systems are built on massive swathes of public web data, assembled into corpora such as C4, RefinedWeb, and Dolma. To our knowledge, we conduct the first, large-scale, longitudinal audit of the consent protocols for the web domains underlying AI training corpora. Our audit of 14,000 web domains provides an expansive view of crawlable web data and how consent preferences to use it are changing over time. We observe a proliferation of AI-specific clauses to limit use, acute differences in restrictions on AI developers, as well as general inconsistencies between websites' expressed intentions in their Terms of Service and their robots.txt. We diagnose these as symptoms of ineffective web protocols, not designed to cope with the widespread re-purposing of the internet for AI. Our longitudinal analyses show that in a single year (2023-2024) there has been a rapid crescendo of data restrictions from web sources, rendering ~5%+ of all tokens in C4, or 28%+ of the most actively maintained, critical sources in C4, fully restricted from use. For Terms of Service crawling restrictions, a full 45% of C4 is now restricted. If respected or enforced, these restrictions are rapidly biasing the diversity, freshness, and scaling laws for general-purpose AI systems. We hope to illustrate the emerging crisis in data consent, foreclosing much of the open web, not only for commercial AI, but non-commercial AI and academic purposes.

Stronger Together: on the Articulation of Ethical Charters, Legal Tools, and Technical Documentation in ML

The growing need for accountability of the people behind AI systems can be addressed by leveraging processes in three fields of study: ethics, law, and computer science. While these fields are often considered in isolation, they rely on complementary notions in their interpretation and implementation. In this work, we detail this interdependence and motivate the necessary role of collaborative governance tools in shaping a positive evolution of AI. We first contrast notions of compliance in the ethical, legal, and technical fields; we outline both their differences and where they complement each other, with a particular focus on the roles of ethical charters, licenses, and technical documentation in these interactions. We then focus on the role of values in articulating the synergies between the fields and outline specific mechanisms of interaction between them in practice. We identify how these mechanisms have played out in several open governance fora: an open collaborative workshop, a responsible licensing initiative, and a proposed regulatory framework. By leveraging complementary notions of compliance in these three domains, we can create a more comprehensive framework for governing AI systems that jointly takes into account their technical capabilities, their impact on society, and how technical specifications can inform relevant regulations. Our analysis thus underlines the necessity of joint consideration of the ethical, legal, and technical in AI ethics frameworks to be used on a larger scale to govern AI systems and how the thinking in each of these areas can inform the others.

Testing Hateful Speeches against Policies

In the recent years, many software systems have adopted AI techniques, especially deep learning techniques. Due to their black-box nature, AI-based systems brought challenges to traceability, because AI system behaviors are based on models and data, whereas the requirements or policies are rules in the form of natural or programming language. To the best of our knowledge, there is a limited amount of studies on how AI and deep neural network-based systems behave against rule-based requirements/policies. This experience paper examines deep neural network behaviors against rule-based requirements described in natural language policies. In particular, we focus on a case study to check AI-based content moderation software against content moderation policies. First, using crowdsourcing, we collect natural language test cases which match each moderation policy, we name this dataset HateModerate; second, using the test cases in HateModerate, we test the failure rates of state-of-the-art hate speech detection software, and we find that these models have high failure rates for certain policies; finally, since manual labeling is costly, we further proposed an automated approach to augument HateModerate by finetuning OpenAI's large language models to automatically match new examples to policies. The dataset and code of this work can be found on our anonymous website: https://sites.google.com/view/content-moderation-project.