Almost all the muscles, and bones, of which the human form is composed, have more, or less of these kind of twists in them; and give in a less degree, the same kind of appearance to the parts which cover them, and are the immediate object of the eye: and for this reason it is that I have been so particular in describing these forms of the bent, and twisted, and ornamental horn.

Yet, properly speaking, no living creatures are capable of moving in such truly varied and graceful directions, as the human species; and it would be needless to say how much superior in beauty their forms and textures likewise are. And surely also after what has been said relating to figure and motion, it is plain and evident that nature has thought fit to make beauty of proportion, and beauty of movement, necessary to each other: so that the observation before made on animals, will hold equally good with regard to man: i. e. that he who is most exquisitely well-proportioned is most capable of exquisite movements, such as ease and grace in deportment, or in dancing.

Document title

Confusingly similar titles of the National framework for the assurance of AI in government and this pilot Australian Government assurance framework, even though they are very different documents. The pilot framework could be considered an assessment form or tool, with fields for users to populate, rather than a traditional, static ‘framework’ document. It is intended to complement and inform existing governance and assurance processes, rather than provide a standalone, comprehensive ‘assurance’ mechanism.

Proposed response

Title will be updated to: Australian Government AI impact assessment tool. 

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Assessment format

Some participants felt providing a digital tool for the assessment would be useful, if it helped streamline the process and make assessments more robust through features like business rules and branching questions. Several participants took the initiative to convert the document into a basic Microsoft Forms template for the pilot.  

However, others preferred the existing Word document format, with a single document providing an overview of the full assessment process, where version history is preserved as the assessment is updated. They felt a document format is more familiar and user-friendly, and queried whether a digital tool would meet record keeping requirements.  

Proposed response

Explore options for a digital tool that meets key requirements, including version history tracking, record keeping, accessibility, easy navigation.  

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Appendix B: Survey questions

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Context, data and rationale

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Appendix A: Pilot agencies

It comes then to this, that no longer than whilst we suppose all the lengths and breadths of the body, or limbs, to be as regular figures as cylinders, or as the leg, figure 68 in plate I, which is as round as a rolling-stone, are the measures of lengths to breadths practicable, or of any use to the knowledge of proportion: so that as all mathematical schemes are foreign to this purpose, we will endeavour to root them quite out of our way: therefore I must not omit taking notice, that Albert Durer, Lamozzo, (see two tasteless figures taken from their books of proportion [Fig. 55. P. I.]) and some others, have not only puzzled mankind with a heap of minute unnecessary divisions, but also with a strange notion that those divisions are governed by the laws of music; which mistake they seem to have been led into, by having seen certain uniform and consonant divisions upon one string produce harmony to the ear, and by persuading themselves, that similar distances in lines belonging to form, would, in like manner, delight the eye

Initiative 1

Some persons have the network so equally wove over the whole body, face and all, that the greatest heat or cold will hardly make them change their colour; and these are seldom seen to blush, tho’ ever so bashful, whilst the texture is so fine in some young women, that they redden, or turn pale, on the least occasion.

Lead agency: Department of Government

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Initiative 2

I am apt to think the texture of this network is of a very tender kind, subject to damage many ways, but able to recover itself again, especially in youth. The fair fat healthy child of 3 or 4 years old hath it in great perfection; most visible when it is moderately warm, but till that age somewhat imperfect. 

Lead agency: Department of Government

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Initiative 3

I am apt to think the texture of this network is of a very tender kind, subject to damage many ways, but able to recover itself again, especially in youth. The fair fat healthy child of 3 or 4 years old hath it in great perfection; most visible when it is moderately warm, but till that age somewhat imperfect. 

Lead agency: Department of Government

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Initiative 4

I am apt to think the texture of this network is of a very tender kind, subject to damage many ways, but able to recover itself again, especially in youth. The fair fat healthy child of 3 or 4 years old hath it in great perfection; most visible when it is moderately warm, but till that age somewhat imperfect. 

Lead agency: Department of Government

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APS AI Plan on a page

Document title

Confusingly similar titles of the National framework for the assurance of AI in government and this pilot Australian Government assurance framework, even though they are very different documents. The pilot framework could be considered an assessment form or tool, with fields for users to populate, rather than a traditional, static ‘framework’ document. It is intended to complement and inform existing governance and assurance processes, rather than provide a standalone, comprehensive ‘assurance’ mechanism.

Proposed response

Title will be updated to: Australian Government AI impact assessment tool.

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Assessment format

Some participants felt providing a digital tool for the assessment would be useful, if it helped streamline the process and make assessments more robust through features like business rules and branching questions. Several participants took the initiative to convert the document into a basic Microsoft Forms template for the pilot.  

However, others preferred the existing Word document format, with a single document providing an overview of the full assessment process, where version history is preserved as the assessment is updated. They felt a document format is more familiar and user-friendly, and queried whether a digital tool would meet record keeping requirements.  

Proposed response

Explore options for a digital tool that meets key requirements, including version history tracking, record keeping, accessibility, easy navigation.  

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Definition of AI

Some agencies felt that the current OECD AI definition could capture a range of longstanding rules-based systems that would not traditionally be considered AI.  

Proposed response

Consider clarifying advice in the AI policy to distinguish AI from other rules-based systems – e.g. highlighting levels of autonomy and inference as factors. Consider including examples to illustrate AI and non-AI systems.  

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‘Covered use case’ criteria

Some concern that the current criteria for a covered AI use case are overly broad and would effectively capture all use cases. The criterium capturing any AI use cases that ‘materially influence decision-making’ was highlighted as particularly broad, as it could be interpreted to capture most government activities.

Proposed response

Consider amending criteria and moving the ‘covered use case’ criteria into the AI policy. The assessment should include a field to record which criteria apply to the assessed use case. The overly-broad criterium mentioned above could be amended to clarify it is referring to substantive administrative decisions – not inconsequential day-to-day decisions.

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Should all existing use cases require assessment – or only new ones?

Some agencies raised concerns about the burden of retroactively assessing dozens of existing use cases and felt any future mandatory assessment should only apply to new use cases.  

Proposed response

The AI policy applies to all AI use by in-scope Australian Government agencies, including existing and new AI use cases. Any future AI use case governance requirements should align with this and likewise apply to all AI use cases. Existing AI use cases should be subject to the same governance and assurance processes as new ones, while providing a transition period to support implementation. A 2-tier approach, exempting certain use cases from scrutiny, would be inconsistent with the government’s commitment to build public trust through robust governance.

Proposed AI policy updates will specify AI use case level governance processes and establish a timeframe for agencies to review existing use cases (e.g. up to 18 months). The impact assessment and guidance will be updated to align with the policy and include further guidance on best practice for assuring existing use cases.

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Timing for the initial assessment

The pilot version recommends users undertake AI impact assessment ‘as early as possible’, however participants noted it may not be possible to complete an assessment in the early development stages of an AI use case. Related to this, participants queried how impact assessment might interact with budget and procurement processes.  

Proposed response

Proposed AI policy updates will recommend that assessment should commence as early as possible in the design stage and the initial assessment should be completed before deployment. While completing the full assessment may not be possible in early stages, agencies should familiarise themselves with the assessment and consider its advice on embedding responsible AI practices into system design.

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Timing and nature of regular assessment reviews

The pilot impact assessment tool recommends a review of the assessment in response to material changes in scope or technology, or when a use case moves between lifecycle stages. However, participants noted reassessment at every lifecycle stage transition may not always be practical or necessary. Participants also queried whether review should involve a complete reassessment, or just sections most affected by the change that triggered review, and is renewed executive sponsor sign-off required every time?  

Proposed response

Ensuring assessments are reviewed at regular, planned intervals and/or in response to material changes is essential to good AI governance. Minimum requirements for reassessment intervals will be specified in the AI policy.  

Assessment and guidance updates could deemphasise lifecycle stage transition as the key consideration and include examples of major milestones or material changes that could trigger review. This will include recommending agencies align with their project management frameworks to decide which transition points would warrant reassessment (e.g. change in scope, contract variation, preproduction check, change advisory board, go-no-go).  

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