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      <title-group>
        <article-title>Counterfactual Explanations of Machine Learning Predictions: Opportunities and Challenges for AI Safety</article-title>
      </title-group>
      <contrib-group>
        <aff id="aff0">
          <label>0</label>
          <institution>K.Sokol</institution>
          ,
          <addr-line>Peter.Flach</addr-line>
        </aff>
        <aff id="aff1">
          <label>1</label>
          <institution>Kacper Sokol and Peter Flach Intelligent Systems Laboratory University of Bristol</institution>
          ,
          <country country="UK">UK</country>
        </aff>
      </contrib-group>
      <abstract>
        <p>One necessary condition for creating a safe AI system is making it transparent to uncover any unintended or harmful behaviour. Transparency can be achieved by explaining predictions of an AI system with counterfactual statements, which are becoming a de facto standard in explaining algorithmic decisions. The popularity of counterfactuals is mainly attributed to their compliance with the “right to explanation” introduced by the European Union's General Data Protection Regulation and them being understandable by a lay audience as well as domain experts. In this paper we describe our experience and the lessons learnt from explaining decision tree models trained on UCI German Credit and FICO Explainable Machine Learning Challenge data sets with class-contrastive counterfactual statements. We review how counterfactual explanations can affect an artificial intelligence system and its safety by investigating their risks and benefits. We show example explanations, discuss their strengths and weaknesses, show how they can be used to debug the underlying model, inspect its fairness and unveil security and privacy challenges that they pose.</p>
      </abstract>
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  <body>
    <sec id="sec-1">
      <title>Introduction</title>
      <p>Safety of software-based artificial intelligence (AI) systems
can be achieved in multiple ways. The most fundamental
one is to gain users’ trust by operating it in a transparent and
interpretable way. In turn, this can be achieved by requiring
the AI system to explain its actions and decisions to the user.
Notwithstanding advantages such as fostering understanding
of how a system works, being a tool to debug an AI system
and providing a mechanism to inspect its fairness,
explanations can also cause unintentional security and privacy
vulnerabilities that may compromise the safety of an AI agent.
In this paper we show the advantages of counterfactual
explanations that can help to improve the overall safety of an
AI system and examine security and privacy threats
associated with them in a financial domain.</p>
      <p>
        Whether due to the financial market regulations or
algorithmic transparency and safety expected by the society, the
need for fairness, accountability and transparency of
automated decisions in financial services is undisputed. In this
work, we examine safety aspects of explaining AI-based
loan application and credit scoring systems that use decision
trees with class-contrastive counterfactual statements that,
usually, are expressed in the following form:
“The prediction is &lt;prediction&gt;. Had a small subset
of features been different &lt;foil&gt;, the prediction would
have been &lt;counterfactual prediction&gt; instead.”
We have used such counterfactual explanations with
predictive AI systems trained on two data sets: UCI German
Credit1 – assessing credit risks based on applicant’s personal
details and lending history, and FICO Explainable Machine
Learning (ML) Challenge2 – predicting whether an
individual has been 90 days past due or worse at least once over
a period of 24 months from opening a credit account based
on anonymised credit bureau data. To this end, we train
decision tree models with scikit-learn
        <xref ref-type="bibr" rid="ref1">(Buitinck et al. 2013)</xref>
        –
a Python machine learning library – and generate
counterfactual explanations of selected data points with a custom
algorithm.
      </p>
      <p>Generating and inspecting some of these statements has
provided us with important insights about the limitations,
vulnerabilities and properties of counterfactual explanations
and their effect on the safety of the underlying AI system.
We found that it is important to consider the amount of
information that they reveal about the underlying AI system
and consequences of this leakage. Moreover, there is a fine
line between counterfactual explanations and adversarial
examples, which is an important aspect of this approach,
especially in a financial setting. One example of a misuse of
a counterfactual explanation could be an attempt to game
the FICO credit scoring algorithm3, which is kept as a trade
secret to avoid just that. Also, there is usually more than
just one counterfactual explanation of the same quality and
length, and choosing the most suitable one remains an open
research question.</p>
      <p>Achieving transparency (explainability and
interpretability), fairness and accountability (security and privacy) of AI
algorithms, their training data sets and decisions that they
output are, in general, open problems. Given the pressure
from regulators and society, research in this area has
become a hot topic in recent years. New approaches are being
1https://archive.ics.uci.edu/ml/datasets/
statlog+(german+credit+data)</p>
      <p>
        2https://community.fico.com/s/
explainable-machine-learning-challenge
3https://www.myfico.com/credit-education/
credit-scores/
introduced by researchers and practitioners regularly, either
as theoretical considerations or novel algorithms (both open
source and commercial). Nevertheless, given historical
biases in data
        <xref ref-type="bibr" rid="ref2">(Buolamwini and Gebru 2018)</xref>
        and the fact that
most of the predictive algorithms are designed to optimise
for predictive performance, their social impact is not always
considered. A prominent example of an unexpected
vulnerability affecting high-performing and often “well-validated”
AI systems are adversarial examples
        <xref ref-type="bibr" rid="ref10">(Nguyen, Yosinski, and
Clune 2015)</xref>
        . Given that adversarial data points can affect
any AI system the danger of gaming predictive algorithms
in financial sector is even more concerning.
      </p>
      <p>
        Counterfactual explanations can help us to address some
of these issues. Their most prominent feature is
explaining the reasons behind a particular classification outcome
        <xref ref-type="bibr" rid="ref9">(Miller 2019)</xref>
        . They can also pick up unfair system
behaviour (disparate impact) and unjustified mistreatment of
an individual (disparate treatment)
        <xref ref-type="bibr" rid="ref15">(Zafar et al. 2017)</xref>
        . Given
their concise and easily understandable format they are a
useful tool to identify bugs and errors in the underlying
predictive model
        <xref ref-type="bibr" rid="ref5">(Kulesza et al. 2015)</xref>
        .
      </p>
      <p>Given these advantages, counterfactual explanations are
becoming a de facto standard in explainable artificial
intelligence and their versatility may encourage some
product managers to deploy them into intra-company or
clientfacing applications. Therefore, we decided to investigate
advantages, shortcomings, safety issues and potential dangers
that can affect a predictive model and its explanations when
using counterfactual statements as an explanatory medium.
Our findings are presented from a financial data perspective,
but should generalise to other safety-critical domains. We
hope that these results will prompt the research community
and practitioners to consider these issues before deploying
explainability techniques in their systems. This is
particularly important in the case of sensitive data – e.g. loan
applications – or predictive algorithms that should remain secret.</p>
      <p>Our observations come from discoveries that we have
made while developing and presenting a system that
explains decisions of the underlying predictive model with
counterfactuals. We have demonstrated our approach to: a
lay audience at a local research festival, postgraduate
research students at our university and artificial intelligence
community attending the 27th International Joint Conference
on Artificial Intelligence. These interactions highlighted
some of their expectations, concerns and dislikes regarding
systems such as ours, its possible applications and
counterfactual explanations in general. Here, we synthesise all of
the lessons that we have learnt into four themes
comprising safety of an AI system: explanations, model debugging,
fairness, and security/privacy.</p>
      <p>Our goal here is not to compare one explainability method
against another to find the one that maximises safety of
the underlying AI system by identifying and mitigating its
harmful behaviour. Instead, we take a step back and
reconsider how explainability may affect a predictive system. Our
approach is motivated by an observed lack of evaluation and
analysis of design choices that are made when proposing
new explainability approaches. In our experience, it is
uncommon among contributions in this space to provide a
consideration of privacy, safety, security and adverse effects of
an explanation.</p>
      <p>We start by introducing the system that we used during all
the demonstrations in Section . Then, after introducing the
four aforementioned explainability themes in Sections –, we
review relevant literature (Section ) followed by conclusions
and future work (Section ).</p>
    </sec>
    <sec id="sec-2">
      <title>Class-contrastive Counterfactuals</title>
      <p>
        Class-contrastive counterfactual explanations are
wellsuited for explaining tabular data given their accessibility
and transparency. They are “user-friendly” and compliant
        <xref ref-type="bibr" rid="ref14 ref2">(Wachter, Mittelstadt, and Russell 2018)</xref>
        with the European
Union’s General Data Protection Regulation4 that came into
force in May 2018 requiring organisations that use
algorithmic decision making to provide their explanations on the
client’s request
        <xref ref-type="bibr" rid="ref3">(Goodman and Flaxman 2017)</xref>
        .
Counterfactuals are furthermore versatile enough to explain predictions,
express their fairness and help debug the underlying models.
      </p>
      <p>Therefore, in our research, we decided to use them to
explain logical AI systems, decision trees in particular. Since
we have access to the model’s internal structure our method
guarantees to produce all the possible counterfactuals for a
particular data point. This, in turn, allows us to focus on
the counterfactuals themselves rather than their generation
process and validity. This means that we have full control
over their generation, hence we can tune it to the research
question that we are posing. Whenever possible, we
annotate every feature in a human understandable way (natural
language description), we indicate which features are
actionable from a user’s perspective (e.g. age vs. the number of
credit cards) and we make a note of protected attributes in
the feature space (e.g. gender or race).</p>
      <p>All these meta-data allows us to use our counterfactual
generation process within a conversational system that can
explain automated predictions, check their fairness and
provide actionable suggestions to the user in a casual
conversation. Our system has two interaction modes: a text-based
chat served to the user as a web page and a voice-driven
interaction facilitated by an off-the-shelf virtual personal
assistant device such as Amazon Alexa or Google Home.
Given our meta-annotations and the natural language
interface the user can ask for: the shortest explanation, an
explanation (not) using a particular feature as a foil, an
explanation that is actionable and, finally, whether the prediction
is fair. All of the examples presented below were generated
with this setup deployed on top of two decision trees, one
trained for each data set introduced earlier.</p>
    </sec>
    <sec id="sec-3">
      <title>Explanatory Properties of Counterfactuals</title>
      <p>Counterfactual explanations have many advantages: they are
short and easy to understand; they can be actionable; and
they are interactive and delivered in a natural language,
hence their complexity can be tuned to the recipient’s
requirements. Here are two examples:
4https://publications.europa.eu/s/inbX.
Example 1. Some explanations for the FICO explainable
ML challenge data set:</p>
      <p>The prediction is Bad. It would be Good had the
Number of Satisfactory Trades been less or equal to 10
instead of being 20.</p>
      <p>The prediction is Bad. It would be Good had the
Number of Trades that has Ever been up to 60 Days</p>
      <sec id="sec-3-1">
        <title>Overdue and are marked as Derogatory in the Pub</title>
        <p>lic Record been equal to 0 instead of being 2.</p>
        <p>
          Counterfactual explanations also have some limitations that
are not always explicitly recognised or stated. Firstly, they
can be actionable but they are not causal. In their pure form
they are local and their insights must not be generalised
(which humans tend to do
          <xref ref-type="bibr" rid="ref11">(Rozenblit and Keil 2002)</xref>
          ) to
other data points. Furthermore, there are multiple open
research questions that have to be addressed before deploying
counterfactual explanations in a mission-critical setting.
        </p>
        <p>One question is how to adjust the (language) complexity
of an explanation based on the audience, for example the
difference between one given to a loan applicant and one
provided to a regulator. Moreover, since every
counterfactual is specific to a particular data point, whenever possible,
it should be accompanied by a context so that the recipient
knows the limitations of its generalisation. Finally, there are
usually multiple counterfactuals of the same quality – e.g.,
the same number of features that has been altered – and it
remains an open question how to pick the right one(s) and
whether all of them are of the same importance. If
interpreted incorrectly, it is not impossible for counterfactuals to
have an adverse effect on safety of an AI system by causing
indirect harm to the involved individuals.</p>
      </sec>
    </sec>
    <sec id="sec-4">
      <title>Model Debugging with Counterfactuals</title>
      <p>In addition to their explanatory properties, counterfactuals
can help to identify bugs, errors and mistakes in the
underlying predictive model. Since counterfactuals express logical
conditions, they can be used to automatically identify cases
where the model behaves not as intended.</p>
      <p>Example 2. Some unexpected explanations for the UCI
German Credit data set:</p>
      <p>Your loan application has been declined. If your
savings account had had more than 100 pounds, you had
not had a savings account or its status had been
unknown, your loan application would be accepted.
Your loan application has been declined. Assuming
that you had asked for less or equal to £663 or between
883 and 1285 pounds, instead of 836 pounds, your loan
application would be accepted.</p>
      <p>The first explanation states that it is better not to disclose
information about one’s savings account, or not to have one
at all, than to have only a modest amount of savings. The
second example highlights non-monotonicity of the model,
which arises often with decision trees but might have been
overlooked by the person training the model.</p>
    </sec>
    <sec id="sec-5">
      <title>Algorithmic Fairness with Counterfactuals</title>
      <p>Counterfactual statements can also be used to uncover
disparate treatment – a scenario where changing a value of
a protected attribute affects the classification outcome. As
shown in the example below, counterfactuals are helpful in
auditing fairness of predictive algorithms, thereby
improving their safety by highlighting their harmful behaviour.
Example 3. A biased explanation for the UCI German
Credit data set:</p>
      <p>The outcome of your loan application would have
changed had you been a male (single, married,
separated, divorced or widowed) instead of being a female
(married, separated or divorced).</p>
    </sec>
    <sec id="sec-6">
      <title>Security and Privacy of Counterfactuals</title>
      <p>Finally, we consider the effect of counterfactual
explainability on privacy and security aspects of the underlying AI
system and its training data. Counterfactual explanations can
be used by an adversary to game a model – recall Example 2
where not having a savings account at all is more beneficial
than having a small amount of savings. Therefore an attempt
to make an AI system safer – by making it transparent – may
have the opposite effect. This observation indicates a close
relationship between counterfactual explanations and
adversarial attacks that needs to be addressed before deploying
explainable systems.</p>
      <p>More generally, explanations reveal information about the
underlying model and its training data. This issue is more
prominent for counterfactual explanations than for other
types of explanation since they leak information about
decision boundaries. For example, for logical models these are
the exact feature splits, for k-nearest neighbours these are
training data points and for SVMs these could be the support
vectors. This observation leads to the question: how many
explanations of how many data points does it take to gather
enough information to steal or game a model or its part?</p>
      <p>This is further compounded as there are usually multiple
counterfactual explanations of different length for a single
data point, and revealing all of them can facilitate easier
model stealing. Also, long counterfactuals where the foil is
a conjunction of multiple logical conditions can reveal a big
chunk of a model with just one explanation.</p>
      <p>Example 4. An explanation for the FICO explainable ML
challenge data set that raises security and privacy concerns:
The prediction would have been Good, instead of Bad,
had:
the Number of Instalment Trades With Balance
been less than 3 instead of 3,
the Number of Revolving Trades With Balance
been less than 3 instead of 5,
the Number of Trades that has Ever been up to 60</p>
      <sec id="sec-6-1">
        <title>Days Overdue and are marked as Derogatory in</title>
        <p>the Public Record been equal to 0 instead of 2, and
the Number of Loans taken in the Last 12 Months
been less or equal to 2 instead of 5.</p>
        <p>Therefore, we believe that alongside every explainability
approach the author should provide a critical evaluation of
its privacy and security implications and a discussion about
mitigating these factors to benefit the overall safety of an AI
system.</p>
      </sec>
    </sec>
    <sec id="sec-7">
      <title>Related Work</title>
      <p>
        The most prominent work discussing contrastive and
counterfactual explanations from both computer and social
sciences perspectives is
        <xref ref-type="bibr" rid="ref9">Miller (2019)</xref>
        . The author concludes
that contrastive and counterfactual statements are the most
natural explainability approach for humans interacting with
intelligent systems. Wachter, Mittelstadt, and Russell (2018)
present an optimisation approach to generating
counterfactual statements for differentiable predictive models such as
neural networks, support vector machines and regressors.
        <xref ref-type="bibr" rid="ref12">Tolomei et al. (2017)</xref>
        also use a particular type of
counterfactual statements – involving features, which when tweaked
transform a true negative instance into a one that a model
classifies as positive – generated for tree ensembles and used
for improving on-line advertisements.
        <xref ref-type="bibr" rid="ref7">Kusner et al. (2017)</xref>
        show that, in addition to their explanatory powers,
counterfactual statements can also be used as a tool to audit fairness
of AI agents.
        <xref ref-type="bibr" rid="ref4">Gunning (2017)</xref>
        argued that explainability is an
important step towards achieving safe artificial intelligence
systems.
      </p>
    </sec>
    <sec id="sec-8">
      <title>Conclusions and Future Work</title>
      <p>In this paper we investigated challenges and opportunities
of counterfactual explainability in AI systems. We showed
their advantages – interpretability, fairness and model
debugging – and presented open research questions in this
space. We also discussed security challenges that they pose
focusing on model and training data stealing and gaming.
All our observations are based on experience and are
supported with examples arising in real data from the financial
domain.</p>
      <p>Our experiments have shown that when improving safety
of an AI system by making it more transparent and
explainable, one can unintentionally make it less secure and leak
private data. Examples provided in this paper clearly show
that security and privacy of a predictive model and its
training data can be compromised when the influence of their
explanations on the overall safety of the AI system is not
assessed in the first place. All in all, this demonstrates that
improving safety of an AI system is challenging and may
have unexpected consequences.</p>
      <p>Given the transparency of our counterfactual generation
approach our future work will focus on the security of
predictive logical models when explaining them with
counterfactual statements. In particular, we are interested in
identifying the least number of counterfactual explanations
that are necessary to reverse-engineer or game a predictive
model. Such research can be of importance for domains that
need to find a balance between security and transparency of
their AI systems.</p>
    </sec>
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