I would just add that I think it's a good starting place, but especially in proposed paragraph 11(1)(a), respecting the usage of data, I think there would be advantages to including a disclosure mechanism to be able to understand how the data was labelled and how it was used. I think that would be something that would have an incredibly positive impact, both on the creation of the models and on their implementation.
I think it's a good starting place, but I would include, specifically in that paragraph, the amendments that were proposed with a specific disclosure requirement around data labelling and annotation.