Recommendations

Recommendations for GPAI Providers

As the most prominent challenge we surfaced through this work is the lack of available public summaries, We provide the following recommendations for GPAI providers:

• P1. Ensure the public summary document adheres closely, ideally exactly, to the template provided by the AI office.
• P2. Mention the public summary document in relevant webpages and documents, for example the README in a repository, and under the correct title as utilised by the template.
• P3. For sections in the template for which no information is available or where the fields are not applicable, explicitly state this to avoid ambiguity arising from open-world assumptions.
• P4. Utilise correct and high-quality SEO metadata to help surface published summaries in search engine results.
• P5. Provide a common area or location for all relevant legal documentation through which stakeholders can also access the published summaries.
• P6. Maintain versions of summaries and clearly indicate where to find these in the document.
• P7. Ensure the public summaries contain all pertinent information, and refrain from directing stakeholders to other locations to access this information. Links to external resources that expand upon the details provided in the public summary are helpful but should not be used to avoid providing the information in the public summary.
• P8. To ensure the public summaries are filled in to a high degree, having the correct and up to date information about datasets used in the model development process is necessary, which in turn requires good data governance.

Recommendations for AI Office to improve the template

• R1. Adding more structured questions, i.e. non-narrative, related to provenance and metadata of the document will assist stakeholders in use of summary (e.g. regarding version, published date, link to previous versions).
• R2. A broad document-level field that indicates what to expect, for example, whether the published summary relates to a new model, or a modified model; and if the base model's published summary is available (if yes, a link to it), and if not, then a justification. Ideally, this could be implemented through different versions of the template.
• R3. A guide attached to the template that describes which information should be expected for specific fields would be helpful. Though this information is provided in part within the 'help text' part of the field itself, we found that this could be expanded to cover more use-cases and offer greater guidance.
• R4. Fields as currently should be tested for use by specific stakeholders, for example through a workshop that identifies whether information is clear, comprehensible, useful, etc.
• R5. Specific sections could benefit obligations for other laws beyond AI Act. For example, Section 2.4 User Data regarding GDPR Articles 13 and 14 where providers could provide information (e.g. purpose, legal basis) or a link to external resource (e.g. privacy policy).
• R6. The public summaries being difficult to discover is a barrier for stakeholders. The AI Office could consider making a centralised portal that hosts all public summaries, and which would includes an online form for guiding providers in providing specific information. This would strengthen and simplify transparency and accountability for public summaries and would simplify the enforcement of this obligation at scale.