Comments to the ICO on the Accuracy of Training Data and Model Outputs for Generative AI

ITIF’s Center for Data Innovation submitted comments to the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights, on its generative AI consultation. The Center provided evidence on the third chapter of the consultation relating to the accuracy principle outlined in the UK GDPR, and how this might affect model outputs.

The Center offered a number of recommendations for how the ICO can better evaluate this, including:

1. The ICO should recognise alternative metrics to statistical accuracy in the measure of model performance and reliability.
2. The ICO should refine what information it expects AI developers to disclose about model accuracy and reliability to prevent unnecessary confusion.
3. The ICO should adjust requirements for developers, deployers, and end-users that would not be technically feasible to implement.
4. The ICO should consider the impact of anonymisation techniques on the accuracy principle that remove personally identifiable information.

Read the submission.