Comment by Ramayya Krishnan

Model developers need to document the rights they have to work with the data they are using to train the model. This documentation should also provide information about the source of the data, whether it was public or private, etc. Model developers should respect the right of data owners to opt out of data crawling (robots.txt file) and also provide data owners the opportunity to opt out of the use of their already collected data in model training or tuning. Model developers need to document the standards that were used in bias assessment and demonstrate the analysis that was conducted to assess structural bias in the data. Congress should require standardized documentation and, like audited financial statements, they should be verifiable by a trusted third party (e.g., an auditor).