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Planning and Design
- Requirement 01 Risk management plan for AI system and execution of the plan
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Requirement 02 Organization of an AI governance system
- 02-1 Have you established guidelines and policies on AI governance?
- 02-2 Have you formed an AI governance group and reviewed the composition of the group?
- 02-3 Is the AI governance being supervised to ensure proper implementation?
- 02-4 Has the AI governance group reviewed the differences between the new and previous systems?
- Requirement 03 Development of a plan to test trustworthiness in the AI system
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Data Collection and Processing
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Requirement 04 Provision of detailed information for data utilization
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04-1 Is there detailed information to support the accurate comprehension and utilization of data?
- 04-1a Have you explained the data attributes before and after cleansing?
- 04-1b Have you sorted data into training data and metadata and is there a specification document for each of them?
- 04-1c Have you explained the reason for selecting the protected attributes and whether they were reflected?
- 04-1d Were data labelers trained and have you provided them with work instructions?
- 04-2 Is data provenance documented and managed?
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04-1 Is there detailed information to support the accurate comprehension and utilization of data?
- Requirement 05 Inspection of abnormal data to ensure data robustness
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Requirement 06 Removal of bias in the collected and processed training data
- 06-1 Have you prepared measures to mitigate bias due to human and physical elements in data collection?
- 06-2 Have you analyzed features used in training and prepared selection criteria?
- 06-3 Have you checked and prevented potential biases in data labeling?
- 06-4 Have you conducted sampling to prevent bias in data?
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Requirement 04 Provision of detailed information for data utilization
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AI Model Development
- Requirement 07 Ensuring security and compatibility of the open-source library
- Requirement 08 Removal of bias in the AI model
- Requirement 09 Establishment of defensive measures for AI model attacks
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Requirement 10 Explanation of AI model specifications and the inference results
- 10-1 Do you provide evidence for users to accept the generation process of the model’s inference results?
- 10-2 Have you transparently provided the specification of the model on the AI model specification document?
- 10-3 When needed, do you provide an explanation about the inference results of the AI model?
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System Development
- Requirement 11 Removal of potential bias in the implementation of the AI system
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Requirement 12 Safe mode of AI system and establishment of a process for notification of problems
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12-1 Have you implemented a safe mode that can respond to problems such as attacks, low performance, and social issues?
- 12-1a Have you prepared an exception handling policy for such problems?
- 12-1b Have you implemented a security technique to reinforce the security of the AI system?
- 12-1c Have you considered a decision-making method that includes humans to mitigate the uncertainty of the AI system?
- 12-1d Are guidance and action on handling expected user error provided?
- 12-2 Does the system perform the function of alerting the operator if a problem occurs in the AI system?
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12-1 Have you implemented a safe mode that can respond to problems such as attacks, low performance, and social issues?
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Requirement 13 Improvement of users’ comprehension of the explanation of the AI system
- 13-1 Have you analyzed user characteristics and constraints in the AI system?
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13-2 Have you provided a thorough explanation based on user characteristics?
- 13-2a Have you established criteria for the evaluation of explanation according to user characteristics?
- 13-2b Have you used terms that are appropriate to user characteristics?
- 13-2c Have you used accurate expressions to lead users to specific behaviors and comprehension?
- 13-2d Are the location and timing where an explanation is needed appropriate?
- 13-2e Have you utilized various user survey techniques to evaluate user experience?
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Operation and Monitoring
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Requirement 14 Ensuring traceability and modification history of the AI system
- 14-1 Have you established measures to track the AI system’s decision-making?
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14-2 Have you obtained the modification history of training data and managed the impact of data modifications?
- 14-2a Have you prepared measures to track the data flow and lineage?
- 14-2b Have you developed measures to monitor modifications in the data source?
- 14-2c Have you managed the versions during data change?
- 14-2d Do you provide information to stakeholders when data change?
- 14-2e When new data have been collected, do you reevaluate the performance of the AI model?
- Requirement 15 Explanation about the scope of services provided and the subject of interactions
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Requirement 14 Ensuring traceability and modification history of the AI system
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01-1Have you analyzed risk factors that may arise throughout the life cycle of the AI system?Determine applicability: Consider this question when analyzing various risk factors that can arise from the healthcare AI system, and determine if the requirement has been satisfied.
• Risk management includes identifying, analyzing, evaluating, and treating risks. You must continuously and repetitively perform these four activities at each stage of the life cycle to remove and prevent risks and, ultimately, ensure trustworthiness. “ISO 31000:2018 — Risk management — Principles and Guidelines” introduces the idea, definition, and overall flow of risk management.
• But the methodology of identification, analysis, and evaluation of risk factors that could interrupt the process of ensuring trustworthiness in AI may differ from existing software and hardware systems. ISO/IEC 24028:2020 and “ISO/IEC 23894:2023 — Guidance on risk management” provide the classification of risk factors to be examined from the perspective of trustworthy AI. ISO 14971, the standard related to the risk management of medical devices, can also be referred to.
• The healthcare sector necessitates meticulous analysis of risks due to its nature. It possesses the risk of issues such as uncertainty and unexplainability arising from technological limitations of AI; diagnostics errors such as false positive or false negative; and damage to life due to security issues, including leakage of personal data or biometrics by a third party.
• The International Medical Device Regulators Forum (IMDRF), the US Food and Drug Administration (FDA), and the EU define risk levels of software as a medical device (SaMD). This definition categorizes the risk level of healthcare AI systems by grade, and there are varying processes for obtaining authorization or approvals for each grade [3].