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  <front>
    <journal-meta />
    <article-meta>
      <title-group>
        <article-title>Checking compliance of a system with regulations : towards a formalisation</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Laurence Cholvy</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Claire Saurel</string-name>
          <email>saurelg@cert.fr</email>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>ONERA Centre de Toulouse 2</institution>
          <addr-line>avenue Edouard Belin 31055 Toulouse</addr-line>
          ,
          <country country="FR">France</country>
        </aff>
      </contrib-group>
      <pub-date>
        <year>2008</year>
      </pub-date>
      <fpage>60</fpage>
      <lpage>70</lpage>
      <abstract>
        <p>This paper addresses the problem of checking if an updated system is in compliance with the current regulations which apply on the domain. We rst present the applicative context in which this problem has been met. We sketch a formalisation of the problem of compliance and we show that is can be split in several sub-problems of di erent types, the solutions of which are discussed.</p>
      </abstract>
      <kwd-group>
        <kwd>Compliance</kwd>
        <kwd>regulations</kwd>
        <kwd>formalisation</kwd>
      </kwd-group>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>-</title>
      <p>{ given a system composed of several components,
{ given the set of regulations which rule this system,
{ given a modi cation which is proposed for the system (modi cation
concerning its structure or the way of performing its function),
{ we rst want to be able to check if the modi ed system is in compliance with
regulations. If it is not, we want to help users to understand where are the
causes of non compliance. Users will then have to revise the given regulations
or to revise the proposed modi cation.</p>
      <p>This paper is organized as follows. Section 2 tends to formalise the problem of
checking compliance of a system with regulations. Section 3 analyses more deeply
this problem and shows that it can be split in several sub-problems of di erent
types. Section 4 focuses on the problem of providing the users an assistance to
revise violated regulations. Section 5 mentions some relevant works, the scienti c
domains they belong to (Information Retrieval and Normative Reasoning) being
candidate to provide us with solutions. Section 6 concludes this paper.
2</p>
      <p>Towards a formalisation of the problem of checking
compliance</p>
    </sec>
    <sec id="sec-2">
      <title>The variables of the problem we address are the following.</title>
      <p>De nition 1. new denotes the updated system the compliance of which has to
be checked.</p>
      <p>De nition 2. KB denotes the background knowledge, i.e the knowledge about
the considered environment.</p>
      <p>Example 1. In the ATS case, if the problem is to check the compliance of the ATS
when aircrafts are given a new fuel, then KB may include characteristics and
properties of this new fuel (density, volumic mass, in ammation temperature...),
but also characteristics of airport environment (atmospheric pressure, physical
models...). Any information describing the modi ed ATS when aircrafts are given
a new fuel is in new.</p>
      <p>&gt;From a more formal point of view, new and KB should be modelled in a
common model. For instance, KB could be modelled by ontologies, hierarchy of
concepts, dependance graphs between concepts, or more generally, and this will
be supposed in the rest of the paper, by logical formulas. In the same way, new
could be modelled by sets of nodes in the ontologies, sets of concepts, or more
generally, and this will be supposed in the rest of the paper, by logical formulas.</p>
      <p>Assumption In the following, we will suppose that new is compatible with
KB i.e, KB [ new will be supposed to be a consistent set of formulas.</p>
      <p>Consistency is a prerequisite to the problem of compliance since, if KB [
new is inconsistant, this means that new contradicts the domain knowldege,
thus, building new is impossible. Consequently, the question of checking his
compliance is not posed.</p>
      <p>De nition 3. A regulation r is a triplet: r = &lt; str; refr; normsr; defr &gt;, where
{ str is an ordonned list of the levels which structure the text of r in an
arborescent way.
{ refr denotes the set of other regulations r refers to.
{ normsr denotes the normative contents of r. If n is in normsr, n is assigned
a position label related to str which denotes its position in the arborescent
structure of r.
{ defr is a set of the de nitions of the concepts which are used in the regulation
text.</p>
      <p>Note that several members of normsr may have the same position label. It means
that they are in the same text unit in r.</p>
      <p>What we want here to capture is that a regulation contains information of
very di erent natures :
{ conceptual de nition information (defr) : that is an optional part of the
regulation. Concepts which are ruled by r are de ned in defr.
{ rules (normsr) : that is the core of the regulation. The rules apply on the
real world by stating what is obligatory, permitted or forbidden under which
conditions. Formal modelling rules requires the use of a logical formalism
dedicated with normative reasoning i.e a deontic logic (see section 5). In the
following, we will thus suppose that these rules are modelled by formulas of
such a logic.
{ In a regulation r, conceptual de nition and rules are expressed according a
given structure (str).
{ information about other regulations refr : regulations which inspire the
regulation, regulations which are abrogated by the regulation...One generally
mainly nd it in the head of the text of r.</p>
      <p>
        Example 2. For r being [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ], str = [article; alinea]. That means that r is
composed of several articles, each of them being eventually composed of alineas.
Example 3. Consider now r0 a regulation such that str0 = [part; subpart; article].
If the formula n is in the 2d article of the 3rd subpart of the 1st part of r0, then
the position label assigned to n is [(part; 1); (subpart; 3); (article; 2)].
Example 4. Finally, for r being [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ], refr includes regulations [
        <xref ref-type="bibr" rid="ref16">16</xref>
        ] and [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ].
De nition 4. R = fr1; :::rng denotes the set of all the regulations which apply
on the domain.
Example 5. In the ATS case, the set R of regulations which rule the aeronautic
domain is composed of CEE regulations, national regulations such as
environment code, civil aviation code, and lots of orders and procedures.
      </p>
      <p>Several relations exist in R such as:
{ r2 S r1 is true if regulation r1 is a specialization of regulation r2. S is a
partial pre-order de ned upon R.
{ r2 A r1 is true if regulation r2 abrogates regulation r1 : it means that r1
doesn't apply anymore since r2 applies. A is a partial pre-order de ned
upon R.
{ a binary relation replace so that replace(aij ; akl ) is true if the ith article of
regulation rj replaces the kth article of regulation rl.</p>
      <p>
        Some of relations of this type has been presented in [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ]. Our model represents
a slightly simpli ed form of real regulations, since as for instance, A could
be de ned between text units of regulations, and not only between regulations
(as for the relation replace) . We here suppose that instances of such relations
concerning a regulation r are explicited in refr.
      </p>
      <p>
        Example 6. Let r1 and r2 respectively being regulations [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ] and [
        <xref ref-type="bibr" rid="ref16">16</xref>
        ]. r2 S
r1, because the regulation dealing with rules concerning the Blagnac airport
specializes the regulation about french public air transport.
      </p>
      <p>De nition 5. If R = fr1; :::; rng is the set of regulations which apply on the
domain, we de ne normsR, as the set of all the rules of all the regulations of R,
n
i.e, normsR = [i=1normsri
normsR is thus a set of formulas of a particular deontic logic.</p>
      <p>More formally, we assume that a formal model (formal language and formal
inference denoted j= in the following) has been chosen for modelling and reason
with rules of normR, background knowledge KB and modi cation new2.</p>
      <p>
        In the rest of the paper, we will suppose that normR is consistent i.e is a
consistent set of rules.3
2 Ideally, this formal model is a logic which allows to express and reason with any
type of deontic notions which appear in regulations, any type of knowledge, causal
or temporal, which appear in KB. Such a logic should then be a deontic logic ([
        <xref ref-type="bibr" rid="ref5">5</xref>
        ],
[
        <xref ref-type="bibr" rid="ref8">8</xref>
        ]) allowing to reason with causality and time as well. De ning such a general logic
remains to be done.
3 Notice that consistency of sets of rules has been de ned in [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ] so that, normR is a
consistent set of rules if there is no situation (or state of the world) s, consistent
with KB (i.e possible) such that : s [ normsR j= f alse. This general de nition is
not taken here for simplicity, but notice that if normR is a consistent set of rules
according to this de nition, then normR is a consistent set of rules
      </p>
      <p>Checking compliance is then de ned by checking one of the following
assertions:</p>
    </sec>
    <sec id="sec-3">
      <title>1. \case of permitted modi cation"</title>
      <p>8
j= normsR ! permitted( )
This expresses that all the consequences the system modi cation new (under
context KB) are explicitely permitted by the rules in the regulations. In the
rst case, new could be accepted without any other modi cation since it is
compliant with the regulations.</p>
    </sec>
    <sec id="sec-4">
      <title>2. \case of forbidden modi cation"</title>
      <p>9
9r 2 R
j= normsr ! f orbidden( )
This expresses that the system modi cation, new, has some consequences
(under context KB) which are explicitely forbidden by one regulation In
this case, new cannot be taken into account since it explicitely leads to
violate regulations, unless modifying regulations themselves. Localizing the
very rules which are violated by new is addressed in section 4.
Notice that in the general case, the prohibition is not caused by only one
regulation. So the case of forbidden modi cation should be described by:
9
j= normsR ! f orbidden( )
However, in this paper, we assume that the prohibition is caused by a single
regulation because it simpli es the presentation of localizing violated rules
(see section 4).</p>
    </sec>
    <sec id="sec-5">
      <title>3. \case of a non ruled modi cation"</title>
      <p>9
This expresses that the system modi cation, new, has some consequences
(under context KB) which are neither explicitely permitted nor explicitely
forbidden by the regulations. In this case, it will be possible to accept new
only after an analyse and modi cations of regulations so that consequences
of new are permitted.</p>
      <p>By de nition, these three assertions are exhaustive. Furthermore, they are
exclusive only if normR is consistent. This is the reason why assuming consistency
of rules is a prerequisite to the de nition of compliance.</p>
      <p>Decomposing the problem of checking compliance
Checking compliance can be decomposed into several sub-problems. The idea is
to check compliance only on a subset of R, made of regulations which \apply
at present" and \concerned by new". At this step, the property \being a
regulation concerned by new" remains to be formally de ned. This property could
be de ned so that the test of checking compliance is more e cient in time. It
could also be de ned so that we can help the user (in the second case) to nd
the precise articles of the regulations that are violated.</p>
      <p>{ Problem pb 1 : nd the \regulations which could be violated"
This problem can be divised into two sub-problems as follows:</p>
      <p>Problem pb 1.1 : nd the \regulations which apply at present"
This problem consists in selecting the regulations which are not
abrogated nor replaced by other regulations. In other words, the problem is
to focus only on the regulations that apply at the moment.</p>
      <p>This problem may be de ned by : nd max A (R) 4</p>
      <p>n
Information in [i=1refri will be hepful to solve this sub-problem .
Problem pb 1.2 : nd the \regulations concerned by new"
This problem is a problem of Information Retrieval, the information to
be retrieved being regulations.</p>
      <p>In order to solve it, considering information in [in=1defri (i.e de nitions
of the concepts used in the regulation text) will be necessary.</p>
      <p>The two above sub-problems may be solved in any sequence order : each of
them contributes towards reducing the set of regulations to be considered in
checking compliance.</p>
      <p>Let us denote Rnew the set of the regulations of R which apply at present
and which are concerned by new.
{ Problem pb 2 : checking compliance of new with Rnew</p>
    </sec>
    <sec id="sec-6">
      <title>This comes to check the three assertions:</title>
      <p>8
and j= normsr ! f orbidden( )
9</p>
      <p>and 6j= normsRnew ! permitted( ) and 6j= normsRnew ! f orbidden( )
4 If is a partial pre-order de ned on R, then max (R) is de ned by:
max (R) = fr 2 R : 8r0 2 R; r0 r ) r r0g</p>
      <p>Towards assisting localization of violated rules
In this section, we suppose the case when new doesn't comply with Rnew. I.e,
we assume that the second assertion of problem pb 2 is true.</p>
      <p>RF orbidden = fr 2 Rnew ; 9</p>
      <p>KB[new j=
and
j= normsr ! f orbidden( )g</p>
      <p>RF orbidden denotes the set of regulations which are involved in the cause of
non compliance of new with Rnew under KB.</p>
      <p>In order to assist users in revising such regulations, several kinds of aids may
be proposed to him. Below we sketch some induced problems.</p>
      <p>{ Problem pb 3 : localize a cause of non compliance in a regulation
Let r 2 RF orbidden. This problem consists in:
1. exhibiting the elements in normsr which are involved in a demonstration
of \forbidden modi cation".
2. nding their position label in r (according to str, as de ned in de nition
3).
{ Problem pb 4 : localize the least specialized regulations involved
in non compliance
The problem is to identify the uppest regulations involved in non
compliance, towards the specialization relation de ned on R : in other words, it is
to identify sources (in the specialization or hierarchical sense) of non
compliance.</p>
      <p>Formally : nd max S (RF orbidden)
{ Problem pb 5 : propagate a cause of non compliance in a set of
regulations
The problem is, given a regulation involved in non compliance, to identify
all the regulations which specialize it. These regulations, because they take
their inspiration from the violated regulations, are are also involved as causes
of non compliance.</p>
      <p>
        Formally : let r 2 RF orbidden, nd fr0 2 RF orbidden, r
S r0g.
{ Problem pb 6 : explanation for non compliance The problem is to give
an informative explanation based upon non compliance demonstrations.
This comes to a problem of Explanation Generation, which has been studied
for many years [
        <xref ref-type="bibr" rid="ref20">20</xref>
        ], [
        <xref ref-type="bibr" rid="ref1">1</xref>
        ].
      </p>
      <sec id="sec-6-1">
        <title>Relevant works</title>
        <p>Among the di erent sub-problems we have raised in the previous sections, two
of them are of particular interest. More speci cally, these are: a problem of
information retrieval, the information to be retrieved are regulations (cf problem 1.2)
and a problem of normative reasoning (cf problem 2). These two very di erent
questions have been addressed by many works we mention some of them below.
5.1</p>
        <sec id="sec-6-1-1">
          <title>Information retrieval, regulation retrieval</title>
          <p>
            Information Retrieval is a vast domain of research whose works aim to de ne
models and methods or algorithms, to retrieve information among a large set of
information, like the web space. See [
            <xref ref-type="bibr" rid="ref22">22</xref>
            ] for an interesting overview. The user's
demand is formalised by a query Q (of the form \retrieve documents which
contains terms t1:::tn").
          </p>
          <p>The three most used models in Information Retrieval are the vector space
model, the probabilistic model and the inference network model.</p>
          <p>According to the vector space model, the user query as well as the documents
the query is addressed to, are represented by vectors of terms (words of a given
vocabulary for instance). The score of a document is de ned as a similarity degree
between its vector and the query vector. Several similarity degrees are usually
used, among which the dot product de ned by: if D denotes the document vector
and Q denotes the query vector, then the score of D for Q is:
sim(D; Q) =
n
X di:qi
i=1
where di is the value of the ith component of (D) and qi is the value of the
ith component of (Q). The value di (resp qi) is called the weight of the dith term
in the document (resp, query).</p>
          <p>Various methods for weighting terms have been de ned. All of them are
based on di erent parameters which are : term frequency (words that repeat
several times in a text are considered salient), document frequency (words that
appear in many documents are considered common and are not very indicative
of document content), the number of documents that contain a given term, the
document lenght (in bytes), the average document length (in bytes)...</p>
          <p>As for Probabilistic models, they assume that documents in a collection
should be ranked by decreasing probability of their relevance to a query
(probabilistic ranking principle). Since knowing its true value is impossible, the
probability of relevance of a document to a query has to be estimated. In this family,
the models di er from the way they estimate that probability of relevance.</p>
          <p>Last models are Inference network models. In these models, document
retrieval is modeled as an inference process in an inference network.</p>
          <p>
            Since we consider Regulation Retrieval as a particular case of Information
Retrieval, solving pb 1.2 could be done by adapting a model of Information
Retrieval. For doing so, the de nitions of concepts used in a regulation (i.e the
defr part) has obviously an important role to play in the process. Furthermore,
the very structure of regulations (i.e the str part) is also something particular
which must be taken into account by Regulation Retrieval models to be de ned
([
            <xref ref-type="bibr" rid="ref4">4</xref>
            ], [
            <xref ref-type="bibr" rid="ref9">9</xref>
            ]).
          </p>
          <p>
            Let us also mention [
            <xref ref-type="bibr" rid="ref10">10</xref>
            ], in which the authors de ne a tool to analyse a
regulation and extract rights and duties expressed in the regulation. Legal texts
are annotated in order to identify the agents, their rights (actions that the agents
have the permission to perform under come conditions) and duties (the actions
they have to perform under some conditions)... A semantic model in then built
from these annotations.
          </p>
          <p>
            Let us nally cite [
            <xref ref-type="bibr" rid="ref13">13</xref>
            ], in which the author de nes a legal ontology of the
french Law. Such an ontology could be used as a common concept description
language and links with the defr part of regulations should be establised.
5.2
          </p>
        </sec>
        <sec id="sec-6-1-2">
          <title>Reasoning with regulations, normative reasoning</title>
          <p>Problem pb 2 raises the question of checking if a given formula, (here permitted( )
or f orbidden( )), is implied by some rules (here normsRnew ). This is a particular
case of what is called \normative reasoning" i.e, reasoning with norms.</p>
          <p>
            Reasoning with norms requires at least modelling deontic notions
(permission, prohibition, obligation...). But it also requires modelling individuals (agents
on which obligations, permission and prohibition apply) and properties on
individuals. It sometimes also require modelling several dimensions of time (time of
validity of norms, deadlines...) and di erent types of norms (defeasible norms,
Contrary-to-duties...). To our knowledge, there is no general logical formalism
which allow to reason with so many di erent notions. However, there are several
kinds of formalisms which allow to model some aspects of the norms. These are
deontic logics [
            <xref ref-type="bibr" rid="ref8">8</xref>
            ].
          </p>
          <p>
            Most of deontic logics are modal ones, [
            <xref ref-type="bibr" rid="ref5">5</xref>
            ], since deontic operators are not
very-functional operators (for instance, it may be the case that smoking is
forbidden, even if somebody is smoking). Some of them are based on dynamic logics
[
            <xref ref-type="bibr" rid="ref15">15</xref>
            ], or based on temporal logics, or both [
            <xref ref-type="bibr" rid="ref7">7</xref>
            ]. They also may be non monotonic
[
            <xref ref-type="bibr" rid="ref11">11</xref>
            ], [
            <xref ref-type="bibr" rid="ref23">23</xref>
            ].
          </p>
          <p>
            However, First Order Logic (FOL) can also been used to reason with deontic
notions ([
            <xref ref-type="bibr" rid="ref21">21</xref>
            ], [
            <xref ref-type="bibr" rid="ref14">14</xref>
            ], [
            <xref ref-type="bibr" rid="ref17">17</xref>
            ], [
            <xref ref-type="bibr" rid="ref19">19</xref>
            ], [
            <xref ref-type="bibr" rid="ref12">12</xref>
            ]...) and is a compromise between expressivity
and simplicity. In this case, normative reasoning comes to a problem of theorem
proving in FOL which is solved (at least from a theoretic pioint of view) by
di erent means: provers based on Resolution Rule, tableaux methods, or any
method de ned for the SAT problem.
          </p>
          <p>
            Let us nally mention a very theoretical but interesting work, [
            <xref ref-type="bibr" rid="ref18">18</xref>
            ], in which
the authors de ne a dynamic deontic logic for reasoning with consequences on
permissions and prohibitions, that the modi cation of a policy generates. This
aims at helping the user who wants to modify a regulation, by allowing him/her
to derive the permissions which were valid before the modi cation and which are
no more valid after; or the permissions which become valid after the modi cation
etc.
          </p>
        </sec>
      </sec>
      <sec id="sec-6-2">
        <title>Conclusion</title>
        <p>In this paper we have addressed the problem of checking compliance of an
updated system with regulations. The main contributions are a formalisation of
this problem and its decomposition in several sub-problems of di erent types.
We also sketched some functionalities which could help a user to revise
regulations in case of non compliance. We nally quickly presented relevant litterature,
more precisely Information retrieval and Normative Reasoning, which could o er
solutions.</p>
        <p>Notice however that this work is very preliminary and thus raises many open
questions, the most important one being the de nitions of the solutions of the
di erent sub-problems and their applicability as well. The case named \case of a
non ruled modi cation" has also to be studied. And the model of regulations used
in this work, has to be re ned in order to take into account a ner granularity
of representation. Indeed, for instance, this model does not allow to represent
relations between text units .</p>
        <p>However, even preliminary, this work enlights the complexity of the problem
of checking compliance and the varieties of questions to be solved.</p>
        <p>Acknowledgments. We would like to thank the anonymous reviewers for
their comments which helped us to improve the paper.</p>
      </sec>
    </sec>
  </body>
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