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AIM Toolkit FAQ
Here you’ll find answers to help you use the AIM Toolkit effectively.
Find answers about the AIM Toolkit
1. Why should businesses adopt the AIM Toolkit?
The AIM toolkit is intended to be part of a voluntary competition and consumer compliance program for businesses. Implementing the AIM toolkit would minimize the risk of the business inadvertently engaging in anti-competitive or unfair trading practices. The use of AIM toolkit could also be a mitigating factor in the event of an infringement (where the infringing conduct is one that the AIM toolkit was deployed to safeguard against). Again, the AIM toolkit serves only as a guide, as mentioned in the fact sheet.
2. How often should businesses conduct these self-assessments? Is there a recommended frequency?
For the AIM toolkit to be part of an effective compliance program, CCS recommends conducting the AIM toolkit self-assessment regularly (at least three times), particularly during significant milestones such as:
· Initial AI model deployment
· Before releasing a developed AI model
· When implementing major changes in business policy
Regular assessment helps identify and address key risk areas in a timely manner. For more information on setting up of compliance programs, please refer to Compliance with Competition Law | Competition and Consumer Commission of Singapore.
3. Will CCS have access to any of the data or model uploaded and will CCS be able to see the results of the AIM toolkit?
No, the toolkit runs entirely on the business’s local system, and neither CCS nor any third parties will have access to any of the data, model or information uploaded. CCS will also not be able to see the results of the AIM toolkit once the business has completed it as the AIM toolkit is meant to be a self-assessment toolkit for businesses.
4. Are there plans to update the toolkit as AI technology and regulatory landscapes evolve?
Yes, CCS will monitor developments in the AI space closely and regularly update the AIM toolkit to maintain its relevance as AI technology advances and regulatory landscapes evolve.
5. Will there be any follow-up or support provided to businesses after they complete the self-assessment?
After completing the self-assessment toolkit, businesses may find it helpful to seek independent legal advice about their business practices. Specifically for competition matters, businesses may apply to CCS for a Notification of Guidance/Decision to determine if the conduct complies with the Competition Act. Further details about this process are available at Seek Guidance and Decision | Competition and Consumer Commission of Singapore.
6. How does this toolkit align with or complement other AI governance frameworks or guidelines? Why are these principles different from AI Verify’s?
The AIM toolkit is designed to address competition and consumer protection concerns for businesses developing/deploying AI, complementing other frameworks or AI Verify principles that focus on different concerns (such as AI safety, AI ethics or AI data privacy).
7. How are these principles selected and where do they base from?
The principles from the AIM toolkit are selected with reference from various sources, including but not limited to, (i) UK’s Competition and Markets Authority’s (“CMA”) technical report on AI Foundational Models, (ii) various academic papers on AI and competition, (iii) cases relating to AI models from other jurisdictions and (iv) some applicable existing principles under IMDA’s AI Verify.
8. Can businesses use the AIM toolkit as a standalone toolkit?
Yes, the AIM toolkit functions as a standalone toolkit, focusing specifically on competition and consumer protection considerations. While it can be accessed as a plugin within AI Verify, its principles remain separate from AI Verify's testing framework. However, for a comprehensive assessment on business’s AI model and practices, businesses are encouraged to use both the AIM toolkit and AI Verify toolkit.
9. Are there any file size limits when using the AIM toolkit?
Yes. The AIM toolkit has a file size limit of 4GB for each input (data/model) uploaded.
10. What forms of documentation would CCS consider when assessing if the use of the AIM toolkit qualifies for the mitigating factor in the event of an infringement?
Businesses are encouraged to keep proper records each time the AIM toolkit is run. Records may include (but are not limited to): (i) the date and time the AIM toolkit was run, (ii) the original reports generated by the AIM toolkit, (iii) explanations for why certain checks or tests were skipped, and (iv) any follow-up actions taken after the AIM toolkit was run. In the event of an infringement, these documents may be taken into consideration by CCS in assessing if the use of the AIM toolkit by the business should qualify as a mitigating factor.