I'm going to remain skeptical about transparency because I think that algorithmic impact assessment isn't a transparency proposal. I think that those proposals, as their title implies, owe a debt to environmental impact assessment. There may be elements of transparency required in producing such an assessment, but I think that I didn't mention them in that section in part because I don't see them as predominantly a transparency approach.
I'd be happy to give you additional skepticism about algorithmic impact assessments, though. The challenge of them, for me, is that we might group the negative harms of algorithms and AI into two groups. One group we could say is foreseeable, and one group we could say is not foreseeable. I'm afraid that the second group is quite large. The algorithmic impact assessment stuff that I've seen really takes for granted that it's possible to have some assessment. When we look at many of the scandals involving computer systems, artificial intelligence and algorithmic systems, a number of the scandals—although not all—seem to involve things that no one would have wanted. It could be that an impact assessment process caused or required the developer to think more carefully about the system and to produce a different one, but it might also be that some of the results that we're seeing are hard to imagine as being foreseen at all. I just worry about it.