Thanks, very helpful. One question - when you do proxy testing, you are bound to find some correlation with protected characteristics (even if small). How do you determine what level of correlation is regarded as problematic?
That's the million dollar question! In the NYS law, the guidance is minimal in this regard: "Whether ECDIS correlates with a protected class may be determined using data available to the insurer or may be reasonably inferred using accepted statistical methodologies." However, correlations between variables exist on a continuum, so companies will the to find an external reference, ideally from the insurance industry. This resource is pretty good, but they focus much more on the disparate impact testing (citing the 4/5ths rule) as opposed to correlation thresholds. www.actuary.org/sites/default/files/2023-08/risk-brief-discrimination.pdf In short, the company gets to decide as long as they have a credible reference.
Great session!
Thanks, very helpful. One question - when you do proxy testing, you are bound to find some correlation with protected characteristics (even if small). How do you determine what level of correlation is regarded as problematic?
That's the million dollar question! In the NYS law, the guidance is minimal in this regard:
"Whether ECDIS correlates with a protected class may be determined using data available to the insurer or may be reasonably inferred using accepted statistical methodologies."
However, correlations between variables exist on a continuum, so companies will the to find an external reference, ideally from the insurance industry. This resource is pretty good, but they focus much more on the disparate impact testing (citing the 4/5ths rule) as opposed to correlation thresholds. www.actuary.org/sites/default/files/2023-08/risk-brief-discrimination.pdf
In short, the company gets to decide as long as they have a credible reference.