Intuitively, if the actual value of an input feature isnot needed (i.e., can be replaced with aconstant) toarriveatsimilar (stable) outcomes for most prediction instances, then theuseofthefeature violates thedata minimization principle.

In this paper, we focus on auditing black-box prediction models for compliance with the GDPR's data minimization principle. This principle restricts prediction models to use the minimal information that is necessary for performing the task at hand. Given the challenge of the black-box setting, our key idea is to check if each of the prediction model's input features is individually necessary by assigning it some constant value (i.e., applying a simple imputation) across all prediction instances, and measuring the extent to which the model outcomes would change. We introduce a metric for data minimization that is based on model instability under simple imputations. We extend the applicability of this metric from a finite sample model to a distributional setting by introducing a probabilistic data minimization guarantee, which we derive using a Bayesian approach. Furthermore, we address the auditing problem under a constraint on the number of queries to the prediction system.

Missing data is prevalent in tabular machine learning (ML) models, and different missing data treatment methods can significantly affect ML model training results. However, little is known about how ML researchers and engineers choose missing data treatment methods and what factors affect their choices. To this end, we conducted a survey of 70 ML researchers and engineers. Our results revealed that most participants were not making informed decisions regarding missing data treatment, which could significantly affect the validity of the ML models trained by these researchers. We advocate for better education on missing data, more standardized missing data reporting, and better missing data analysis tools.

In this paper, we focus on auditing black-box prediction models for compliance with the GDPR's data minimization principle. This principle restricts prediction models to use the minimal information that is necessary for performing the task at hand. Given the challenge of the black-box setting, our key idea is to check if each of the prediction model's input features is individually necessary by assigning it some constant value (i.e., applying a simple imputation) across all prediction instances, and measuring the extent to which the model outcomes would change. We introduce a metric for data minimization that is based on model instability under simple imputations. We extend the applicability of this metric from a finite sample model to a distributional setting by introducing a probabilistic data minimization guarantee, which we derive using a Bayesian approach. Furthermore, we address the auditing problem under a constraint on the number of queries to the prediction system.