Navigating EU AI law: Google Cloud's proactive approach

AI governance has reached a major milestone in the European Union: the AI ​​Act has been published in the EU Official Journal and will come into effect on August 1st. The AI ​​Act is a legal framework that establishes obligations for AI systems based on their level of potential risk and impact. It will be phased in over the next 36 months and includes prohibitions on certain practices, general-purpose AI rules, and obligations for high-risk systems. Importantly, the Act's yet-to-be-developed AI Code of Practice will establish compliance requirements for a subset of general-purpose AI.

At Google, we believe in the potential of AI for society and know how important it is to mitigate the risks. Today, we're summarizing the following:

How we currently support AI customers

How were you preparing to comply with this new law?

What customers can do

How Google Cloud is currently supporting AI customers

We offer data protection. We are committed to building privacy protections into our cloud architecture. We provide meaningful transparency around our data use, including clear disclosures and commitments around access to your data and a long-standing commitment to GDPR compliance. We continue this commitment with Generative AI. Google Cloud will not use customer-provided data to train models without your permission.

In a standard generative AI implementation for an enterprise customer, any organizational data stored remains in the customer's cloud environment.

Importantly, as outlined in the Google Cloud Platform Terms of Service and Cloud Data Processing Addendum, organizations have control over how their data is accessed, used, and processed, and we provide customers with visibility into who can access their data and why.

Additionally, customers have control over the tuning of the underlying model. They can tune a specific underlying model for a specific task without rebuilding the entire underlying model. Each tuning job creates additional adapter weights, which are learned parameters. Adapter weights are customer specific and only available to the customer who tuned them.

During inference, the underlying model receives adapter weights, executes requests and returns results. Customers can manage the encryption of stored adapters generated during training using Customer Managed Encryption Keys (CMEK), and can delete adapter weights at any time.

We invest in comprehensive risk management. Rigorous assessment is essential to the success of AI that adheres to security, privacy and safety standards. Clouds' commitment to risk management was demonstrated in a recent AI readiness assessment of our efforts by Coalfires.

Internally, we continue to invest in comprehensive AI risk assessments, frequently refining our risk process and taxonomy based on ongoing research into new and evolving AI risks, user feedback, red team testing results, and other engagements. The technical details and context of AI use vary by product and must be assessed separately. A key element of these analyses includes consideration of the role Google Cloud and our customers play in ensuring safe and secure deployments.

Google is leading on AI safety and responsibility. We are committed to leading responsible AI development and will continue to oversee our governance process in accordance with our long-standing AI Principles. We have identified certain areas we will not pursue, including technologies that could cause harm, violate international law or human rights, or enable surveillance that violates acceptable norms.

These values ​​are also embedded in our Google Cloud Platform Acceptable Use Policy and our Prohibited Uses for Generative AI Policy, making them transparent and communicated to our customers.

We support transparency. We firmly believe that building trust is essential for the long-term success of AI, and that starts with a commitment to transparency. Google has led the world in supporting the concept of model cards, which provide a shared understanding of model capabilities and limitations and help customers and researchers understand how we train and test our generative models.

In addition to model-specific details, our paper on Approaches to Trust in Artificial Intelligence outlines how to identify, assess, and mitigate potential harmful impacts as part of an end-to-end process. We remain committed to sharing the latest research covering topics such as responsible AI, security, privacy, and anti-abuse.

We support our customers on security, copyright, and portability issues. We believe we are in the same boat as our customers and recognize that responsible AI requires an ecosystem approach. We offer enterprise protection with generative AI copyright indemnification and don't charge egress fees, so customers are free to choose the most responsible provider without fear of being locked into a model. We also develop responsible AI tools, enablement, and support, allowing customers to customize their own risk and safety posture for each use case and each deployment.

Our Secure AI Framework (SAIF) helps Google Cloud customers assess the relevance of traditional security risks and controls and determine how they need to adapt or extend them to cover AI systems. We also hope to support customers as they look to establish their AI strategy by sharing guidance and best practices on topics like AI governance and AI security.

How Google Cloud is preparing for AI law compliance

Internally, our AI Act readiness program is focused on ensuring our products and services comply with the requirements of the Act while continuing to deliver the innovative solutions our customers expect. It's a company-wide effort that involves collaboration across many teams, including:

Law and Policy: We are thoroughly analyzing the requirements of the AI ​​Act and working to integrate it into existing policies, practices, and contracts.

Risk and Compliance: Assess and mitigate potential risks related to compliance with AI laws and ensure robust processes are in place.

Product and Engineering: Ensuring that our AI systems are designed and built with the AI ​​Act’s principles of transparency, accountability, and fairness in mind, and that we continuously improve the user experience by incorporating the AI ​​Act’s requirements for testing, monitoring, and documentation.

Client Engagement: We work closely with clients to understand their needs and concerns regarding AI law and provide guidance and support where required.

How Google Cloud customers can prepare for AI law

The AI ​​Act is a complex piece of legislation, and the details of how it will be implemented are still being debated within the European Commission and the AI ​​Office. As the AI ​​Office moves forward and implementation guidance continues to evolve, it is important to familiarize yourself with the requirements of the AI ​​Act and how they apply to your current or future uses of AI.

For Google Cloud customers interested in preparing for AI law, we have several recommendations:

Follow the developments in the Code of Conduct and the AI ​​Office forum as discussions continue over the coming months to determine the compliance basis for General Purpose AI (GPAI) models. Stay informed about how your organization is using GPAI and where your compliance obligations lie.

Engage with European regulators and industry associations: AI legislation can help boost competitiveness, productivity, and innovation opportunities in Europe, but only if it is implemented in line with international best practices and with real use cases in mind. Engage with industry associations and European regulators to share how your company is using AI and the value and benefits it will bring to your business in the future.

Review your AI governance practices: The AI ​​Act sets out several requirements for AI oversight. You should review your governance practices to ensure they meet the requirements of the Act. It is beneficial to assess the risk level of your AI systems and your overall data governance program as it will help with your explainability and transparency efforts.

While the EU AI Law provides a framework for AI regulation, there are still areas that require continued attention and clarification. We are committed to open dialogue and collaboration to address concerns and ensure the benefits of AI are available to all while mitigating potential risks.

As we prepare, we remain focused on delivering cutting-edge AI solutions to our enterprise customers that are innovative and compliant. We have the capabilities and experience to continue partnering with policymakers and customers as new regulations, frameworks and standards are developed.

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