DATA/ AI Ethics Framework for ANZ Bank
Introduction
Frazer Walker was engaged to help develop and implement a data and AI algorithmic ethics framework for the bank.
The bank, as part of its enterprise data governance function, aimed to develop a pragmatic framework for use across the bank to aid decision making on development, use and governance of its key data assets and key AI/ML algorithms.
The Challenge
One dimension of the framework was ensuring alignment to the bank’s corporate culture and values and the Ethics, Environmental, Social and Governance Committee’s charter and objects.
Another was alignment to developing worldwide practices in accountability, transparency and fairness.
Our Work
Frazer Walker was commissioned initially to develop a data/AI ethics framework and the engagement approach then changed to focus on developing data/AI ethics principles.
That then pivoted towards a research piece, which would contribute to the framework.
FW also developed detailed statements that underpinned the principles; wrote a draft Data/AI Ethics Standard; described 25 themes relevant to data/AI ethics such as bias and dark patterns; and produced draft guiderails, or internal risk assessment tools to assist staff when using data and AI algorithms.
The standard and guiderails were modelled on existing documentation to align with pre-existing formats. The specific guiderails for identified customer data, de-identified & anonymised customer data, and non-customer data include a tailored data ethics canvas of questions to help identify potential ethical issues.
FW spent time understanding the bank’s purpose, values and culture, and its sustainability framework that describes its approach to ESG, current priority areas and material issues.
FW consulted its internal bank of data/AI ethics principles for private, public and NFP organisations. Evaluating what others have disclosed versus the client’s direction, informed where changes could be made.
The Outcome
The work completed by Frazer Walker informs the thinking for the Data/AI Ethics Framework now being implemented across the bank, and how the bank operationalises data/AI ethics into the collection, use and disclosure of data, subsequent analysis, building algorithmic models, generating insights, and making ethical decisions.
FW has substantially contributed to the client’s journey in establishing a data/AI ethics practice that is committed to the ethical collection, use, disclosure and decisioning of data and AI algorithms.