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On your specific text: - What if the AI is supplied by a vendor but runs on a computer system controlled by the user or by a third party? This could happen if the user doesn’t want, or isn’t allowed, to disclose the inputs or their derivatives. - Assuming there’s a need to mandate cryptographic digital signatures at all, why require certificates and PKI? Wouldn’t it suffice for the signer to announce a public key and, if necessary, its revocation? - Cryptographic signatures are still overwhelmingly the exception, not the rule, in legal evidence. Courts routinely admit ordinary paper and electronic business records, authenticated, when necessary, by their creators or custodians. (See, for example, Rules 901 and 902 in the Federal Rules of Evidence.) Digital signatures might not make this easier; consider the potential for conflicting expert testimony about signing and key management schemes and their weaknesses. More generally: As a professional engineer who uses my own and others’ software, I don’t think an AI model is fundamentally different from a spreadsheet, a card deck with a FORTRAN program, or a table or formula in a printed handbook. If I’m relying on something for my work, it’s my professional responsibility to assess its validity, suitability for purpose, and limitations; to know how to use it properly; and to interpret and evaluate its output. The standard of care with which I do those things, the nature and extent of any documentation I might produce, and the arrangements for the retention, protection, and future authentication of those materials in case of a dispute, will vary with the circumstances, including the potential for harm to the client or to the public and my own organization’s appetite for risk. Perhaps your context is different, but I hesitate to endorse a highly prescriptive approach. Engineering regulators use very broad language; for example, Florida’s rule says only, “The engineer shall be responsible for the results generated by any computer software and hardware that he or she uses in providing engineering services” [1], and Professional Engineers Ontario has guidelines [2] but not specific standards. [1] Florida Administrative Code, Rule 61G15-30.008 [2] “Professional Engineers Using Software-Based Engineering Tools,” April 2011, https://www.peo.on.ca/sites/default/files/2019-07/Profession... |
> why require certificates and PKI
to buy down risk in a highly regulated sector. Tesla has been doing this internal to their cars for a while now. Inferences from the ML computers are signed and compared, and the path software. And there's already a pile of PKI options available.
> it’s my professional responsibility to assess its validity, suitability for purpose, and limitations; to know how to use it properly; and to interpret and evaluate its output.
I commend that approach, unfortunately, policy at a national level has to assume there are bad actors. The problem in my profession is that anything more than some light algebra to calculate basic statistics is completely out of their skill set. Additionally, the practitioners are so bound by other policy, they basically have to be compelled to do anything more.