Purpose
Clause 4 starts the bias work by fixing the system's bias requirements and boundaries before any data or model work.
What clause 4.1 asks
The first step sets the terms before any data or model work. It asks what part bias plays in this system, rather than starting from a metric. The step adds tasks to the ordinary development process and creates the record that later steps will use. It also introduces the split between bias the system needs and bias that causes harm, because the requirement cannot be written without that split.
Why it matters
Starting with the model is the most common sequencing error. A team trains a model, measures a disparity, and then tries to decide whether the disparity is a problem. Clause 4 reverses that order. It asks what the system is for, which differences are intended, which differences would harm people, and what boundaries make the intended use appropriate. Only then can a metric be chosen. The clause also creates the profile early, so the later steps have somewhere to write.
What good looks like
Run a clause 4 workshop before the first data extract. Bring the business owner, the designer, the operator, the legal or policy lead and at least one person who represents an affected group. Produce the bias requirements, the boundaries of acceptability, the values statement and the first version of the profile. Record the disagreements as well as the conclusions, because a later assessor will want to know why a boundary was drawn where it was.
Evidence an assessor asks for
The assessor will ask for the bias requirements before looking at the model metrics. If the requirements were written after the tests, the assessor cannot tell whether the tests were chosen to fit the result.
- Bias requirements The written requirements for wanted and unwanted bias, with the rationale for each
- Boundaries of acceptability The conditions under which the system's differential treatment is acceptable, and the conditions that take it outside
- Values statement The organization's values and the first view of bias for this system
- Profile version 1 The first bias profile, dated and indexed
Where it commonly fails
- The first artefact is a model card, with no bias requirement
- Boundaries are described as user instructions rather than validated limits
- The values statement is copied from the corporate code with no system-specific content
What to do before publication
Hold the workshop before the first data extract and record the dissent. The profile starts here, not at the evaluation stage.