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byAK and the research community

Aug 27

The Data Provenance Initiative: A Large Scale Audit of Dataset Licensing & Attribution in AI

The race to train language models on vast, diverse, and inconsistently documented datasets has raised pressing concerns about the legal and ethical risks for practitioners. To remedy these practices threatening data transparency and understanding, we convene a multi-disciplinary effort between legal and machine learning experts to systematically audit and trace 1800+ text datasets. We develop tools and standards to trace the lineage of these datasets, from their source, creators, series of license conditions, properties, and subsequent use. Our landscape analysis highlights the sharp divides in composition and focus of commercially open vs closed datasets, with closed datasets monopolizing important categories: lower resource languages, more creative tasks, richer topic variety, newer and more synthetic training data. This points to a deepening divide in the types of data that are made available under different license conditions, and heightened implications for jurisdictional legal interpretations of copyright and fair use. We also observe frequent miscategorization of licenses on widely used dataset hosting sites, with license omission of 72%+ and error rates of 50%+. This points to a crisis in misattribution and informed use of the most popular datasets driving many recent breakthroughs. As a contribution to ongoing improvements in dataset transparency and responsible use, we release our entire audit, with an interactive UI, the Data Provenance Explorer, which allows practitioners to trace and filter on data provenance for the most popular open source finetuning data collections: www.dataprovenance.org.

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.

SafeSynthDP: Leveraging Large Language Models for Privacy-Preserving Synthetic Data Generation Using Differential Privacy

Machine learning (ML) models frequently rely on training data that may include sensitive or personal information, raising substantial privacy concerns. Legislative frameworks such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) have necessitated the development of strategies that preserve privacy while maintaining the utility of data. In this paper, we investigate the capability of Large Language Models (LLMs) to generate synthetic datasets integrated with Differential Privacy (DP) mechanisms, thereby enabling data-driven research and model training without direct exposure of sensitive information. Our approach incorporates DP-based noise injection methods, including Laplace and Gaussian distributions, into the data generation process. We then evaluate the utility of these DP-enhanced synthetic datasets by comparing the performance of ML models trained on them against models trained on the original data. To substantiate privacy guarantees, we assess the resilience of the generated synthetic data to membership inference attacks and related threats. The experimental results demonstrate that integrating DP within LLM-driven synthetic data generation offers a viable balance between privacy protection and data utility. This study provides a foundational methodology and insight into the privacy-preserving capabilities of LLMs, paving the way for compliant and effective ML research and applications.

From Principle to Practice: Vertical Data Minimization for Machine Learning

Aiming to train and deploy predictive models, organizations collect large amounts of detailed client data, risking the exposure of private information in the event of a breach. To mitigate this, policymakers increasingly demand compliance with the data minimization (DM) principle, restricting data collection to only that data which is relevant and necessary for the task. Despite regulatory pressure, the problem of deploying machine learning models that obey DM has so far received little attention. In this work, we address this challenge in a comprehensive manner. We propose a novel vertical DM (vDM) workflow based on data generalization, which by design ensures that no full-resolution client data is collected during training and deployment of models, benefiting client privacy by reducing the attack surface in case of a breach. We formalize and study the corresponding problem of finding generalizations that both maximize data utility and minimize empirical privacy risk, which we quantify by introducing a diverse set of policy-aligned adversarial scenarios. Finally, we propose a range of baseline vDM algorithms, as well as Privacy-aware Tree (PAT), an especially effective vDM algorithm that outperforms all baselines across several settings. We plan to release our code as a publicly available library, helping advance the standardization of DM for machine learning. Overall, we believe our work can help lay the foundation for further exploration and adoption of DM principles in real-world applications.

Machine Learners Should Acknowledge the Legal Implications of Large Language Models as Personal Data

Does GPT know you? The answer depends on your level of public recognition; however, if your information was available on a website, the answer is probably yes. All Large Language Models (LLMs) memorize training data to some extent. If an LLM training corpus includes personal data, it also memorizes personal data. Developing an LLM typically involves processing personal data, which falls directly within the scope of data protection laws. If a person is identified or identifiable, the implications are far-reaching: the AI system is subject to EU General Data Protection Regulation requirements even after the training phase is concluded. To back our arguments: (1.) We reiterate that LLMs output training data at inference time, be it verbatim or in generalized form. (2.) We show that some LLMs can thus be considered personal data on their own. This triggers a cascade of data protection implications such as data subject rights, including rights to access, rectification, or erasure. These rights extend to the information embedded with-in the AI model. (3.) This paper argues that machine learning researchers must acknowledge the legal implications of LLMs as personal data throughout the full ML development lifecycle, from data collection and curation to model provision on, e.g., GitHub or Hugging Face. (4.) We propose different ways for the ML research community to deal with these legal implications. Our paper serves as a starting point for improving the alignment between data protection law and the technical capabilities of LLMs. Our findings underscore the need for more interaction between the legal domain and the ML community.

Attacks Against Security Context in 5G Network

The security context used in 5G authentication is generated during the Authentication and Key Agreement (AKA) procedure and stored in both the user equipment (UE) and the network sides for the subsequent fast registration procedure. Given its importance, it is imperative to formally analyze the security mechanism of the security context. The security context in the UE can be stored in the Universal Subscriber Identity Module (USIM) card or in the baseband chip. In this work, we present a comprehensive and formal verification of the fast registration procedure based on the security context under the two scenarios in ProVerif. Our analysis identifies two vulnerabilities, including one that has not been reported before. Specifically, the security context stored in the USIM card can be read illegally, and the validity checking mechanism of the security context in the baseband chip can be bypassed. Moreover, these vulnerabilities also apply to 4G networks. As a consequence, an attacker can exploit these vulnerabilities to register to the network with the victim's identity and then launch other attacks, including one-tap authentication bypass leading to privacy disclosure, location spoofing, etc. To ensure that these attacks are indeed realizable in practice, we have responsibly confirmed them through experimentation in three operators. Our analysis reveals that these vulnerabilities stem from design flaws of the standard and unsafe practices by operators. We finally propose several potential countermeasures to prevent these attacks. We have reported our findings to the GSMA and received a coordinated vulnerability disclosure (CVD) number CVD-2022-0057.

RAGent: Retrieval-based Access Control Policy Generation

Manually generating access control policies from an organization's high-level requirement specifications poses significant challenges. It requires laborious efforts to sift through multiple documents containing such specifications and translate their access requirements into access control policies. Also, the complexities and ambiguities of these specifications often result in errors by system administrators during the translation process, leading to data breaches. However, the automated policy generation frameworks designed to help administrators in this process are unreliable due to limitations, such as the lack of domain adaptation. Therefore, to improve the reliability of access control policy generation, we propose RAGent, a novel retrieval-based access control policy generation framework based on language models. RAGent identifies access requirements from high-level requirement specifications with an average state-of-the-art F1 score of 87.9%. Through retrieval augmented generation, RAGent then translates the identified access requirements into access control policies with an F1 score of 77.9%. Unlike existing frameworks, RAGent generates policies with complex components like purposes and conditions, in addition to subjects, actions, and resources. Moreover, RAGent automatically verifies the generated policies and iteratively refines them through a novel verification-refinement mechanism, further improving the reliability of the process by 3%, reaching the F1 score of 80.6%. We also introduce three annotated datasets for developing access control policy generation frameworks in the future, addressing the data scarcity of the domain.

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.

Awareness in Practice: Tensions in Access to Sensitive Attribute Data for Antidiscrimination

Organizations cannot address demographic disparities that they cannot see. Recent research on machine learning and fairness has emphasized that awareness of sensitive attributes, such as race and sex, is critical to the development of interventions. However, on the ground, the existence of these data cannot be taken for granted. This paper uses the domains of employment, credit, and healthcare in the United States to surface conditions that have shaped the availability of sensitive attribute data. For each domain, we describe how and when private companies collect or infer sensitive attribute data for antidiscrimination purposes. An inconsistent story emerges: Some companies are required by law to collect sensitive attribute data, while others are prohibited from doing so. Still others, in the absence of legal mandates, have determined that collection and imputation of these data are appropriate to address disparities. This story has important implications for fairness research and its future applications. If companies that mediate access to life opportunities are unable or hesitant to collect or infer sensitive attribute data, then proposed techniques to detect and mitigate bias in machine learning models might never be implemented outside the lab. We conclude that today's legal requirements and corporate practices, while highly inconsistent across domains, offer lessons for how to approach the collection and inference of sensitive data in appropriate circumstances. We urge stakeholders, including machine learning practitioners, to actively help chart a path forward that takes both policy goals and technical needs into account.

SILO Language Models: Isolating Legal Risk In a Nonparametric Datastore

The legality of training language models (LMs) on copyrighted or otherwise restricted data is under intense debate. However, as we show, model performance significantly degrades if trained only on low-risk text (e.g., out-of-copyright books or government documents), due to its limited size and domain coverage. We present SILO, a new language model that manages this risk-performance tradeoff during inference. SILO is built by (1) training a parametric LM on Open License Corpus (OLC), a new corpus we curate with 228B tokens of public domain and permissively licensed text and (2) augmenting it with a more general and easily modifiable nonparametric datastore (e.g., containing copyrighted books or news) that is only queried during inference. The datastore allows use of high-risk data without training on it, supports sentence-level data attribution, and enables data producers to opt out from the model by removing content from the store. These capabilities can foster compliance with data-use regulations such as the fair use doctrine in the United States and the GDPR in the European Union. Our experiments show that the parametric LM struggles on domains not covered by OLC. However, access to the datastore greatly improves out of domain performance, closing 90% of the performance gap with an LM trained on the Pile, a more diverse corpus with mostly high-risk text. We also analyze which nonparametric approach works best, where the remaining errors lie, and how performance scales with datastore size. Our results suggest that it is possible to build high quality language models while mitigating their legal risk.

Fidelity and Privacy of Synthetic Medical Data

The digitization of medical records ushered in a new era of big data to clinical science, and with it the possibility that data could be shared, to multiply insights beyond what investigators could abstract from paper records. The need to share individual-level medical data to accelerate innovation in precision medicine continues to grow, and has never been more urgent, as scientists grapple with the COVID-19 pandemic. However, enthusiasm for the use of big data has been tempered by a fully appropriate concern for patient autonomy and privacy. That is, the ability to extract private or confidential information about an individual, in practice, renders it difficult to share data, since significant infrastructure and data governance must be established before data can be shared. Although HIPAA provided de-identification as an approved mechanism for data sharing, linkage attacks were identified as a major vulnerability. A variety of mechanisms have been established to avoid leaking private information, such as field suppression or abstraction, strictly limiting the amount of information that can be shared, or employing mathematical techniques such as differential privacy. Another approach, which we focus on here, is creating synthetic data that mimics the underlying data. For synthetic data to be a useful mechanism in support of medical innovation and a proxy for real-world evidence, one must demonstrate two properties of the synthetic dataset: (1) any analysis on the real data must be matched by analysis of the synthetic data (statistical fidelity) and (2) the synthetic data must preserve privacy, with minimal risk of re-identification (privacy guarantee). In this paper we propose a framework for quantifying the statistical fidelity and privacy preservation properties of synthetic datasets and demonstrate these metrics for synthetic data generated by Syntegra technology.

LibVulnWatch: A Deep Assessment Agent System and Leaderboard for Uncovering Hidden Vulnerabilities in Open-Source AI Libraries

Open-source AI libraries are foundational to modern AI systems but pose significant, underexamined risks across security, licensing, maintenance, supply chain integrity, and regulatory compliance. We present LibVulnWatch, a graph-based agentic assessment framework that performs deep, source-grounded evaluations of these libraries. Built on LangGraph, the system coordinates a directed acyclic graph of specialized agents to extract, verify, and quantify risk using evidence from trusted sources such as repositories, documentation, and vulnerability databases. LibVulnWatch generates reproducible, governance-aligned scores across five critical domains, publishing them to a public leaderboard for longitudinal ecosystem monitoring. Applied to 20 widely used libraries, including ML frameworks, LLM inference engines, and agent orchestration tools, our system covers up to 88% of OpenSSF Scorecard checks while uncovering up to 19 additional risks per library. These include critical Remote Code Execution (RCE) vulnerabilities, absent Software Bills of Materials (SBOMs), licensing constraints, undocumented telemetry, and widespread gaps in regulatory documentation and auditability. By translating high-level governance principles into practical, verifiable metrics, LibVulnWatch advances technical AI governance with a scalable, transparent mechanism for continuous supply chain risk assessment and informed library selection.

In-House Evaluation Is Not Enough: Towards Robust Third-Party Flaw Disclosure for General-Purpose AI

The widespread deployment of general-purpose AI (GPAI) systems introduces significant new risks. Yet the infrastructure, practices, and norms for reporting flaws in GPAI systems remain seriously underdeveloped, lagging far behind more established fields like software security. Based on a collaboration between experts from the fields of software security, machine learning, law, social science, and policy, we identify key gaps in the evaluation and reporting of flaws in GPAI systems. We call for three interventions to advance system safety. First, we propose using standardized AI flaw reports and rules of engagement for researchers in order to ease the process of submitting, reproducing, and triaging flaws in GPAI systems. Second, we propose GPAI system providers adopt broadly-scoped flaw disclosure programs, borrowing from bug bounties, with legal safe harbors to protect researchers. Third, we advocate for the development of improved infrastructure to coordinate distribution of flaw reports across the many stakeholders who may be impacted. These interventions are increasingly urgent, as evidenced by the prevalence of jailbreaks and other flaws that can transfer across different providers' GPAI systems. By promoting robust reporting and coordination in the AI ecosystem, these proposals could significantly improve the safety, security, and accountability of GPAI systems.

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.