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These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. http://www.modelop.com/contact These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. ModelOps ModelOp Special Edition by Stu Bailey These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. ModelOps For Dummies®, ModelOp Special Edition Published by: John Wiley & Sons, Inc., 111 River St., Hoboken, NJ 07030-5774, www.wiley.com Copyright © 2022 by John Wiley & Sons, Inc. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning or otherwise, except as permitted under Sections 107 or 108 of the 1976 United States Copyright Act, without the prior written permission of the Publisher. 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Some blank pages in the print version may not be included in the ePDF version. Publisher’s Acknowledgments Some of the people who helped bring this book to market include the following: Project Manager and Development Editor: Carrie Burchfield-Leighton Acquisitions Editor: Ashley Coffey Sr. Managing Editor: Rev Mengle Business Development Representative: William Hull ModelOp Acknowledgments This book is made possible in part by the leading and market defining efforts of Royal Bank of Canada in ModelOps and more broadly Enterprise AI. ModelOp would like to give a special thanks to Gunjan Modha, managing director and head of banking technology & architecture. http://www.wiley.com http://www.wiley.com/go/permissions mailto:info@dummies.biz http://www.wiley.com/go/custompub http://www.wiley.com/go/custompub mailto:BrandedRights&Licenses@Wiley.com Table of Contents iii These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Table of Contents INTRODUCTION ............................................................................................... 1 About This Book ................................................................................... 1 Foolish Assumptions ............................................................................ 2 Icons Used in This Book ....................................................................... 3 Beyond the Book .................................................................................. 4 CHAPTER 1: Realizing that Models are Eating the World ............................................................................................ 7 Tracing the Evolution of Models ......................................................... 8 Understanding the Differences Between Models and Software ....................................................................................... 10 Seeing the Tip of the AI-Iceberg ........................................................ 12 Framing ModelOps for the Exec Team and CEO ............................ 13 CHAPTER 2: Understanding the Role Played by ModelOps in Enterprise AI .......................................... 15 Knowing the Key Requirements for ModelOps .............................. 16 Recognizing that Models Are Enterprise Assets ............................. 18 Understanding the Differences between ModelOps and MLOps .......................................................................................... 19 Introducing the Enterprise AI Team ................................................. 21 Identifying the key stakeholders ................................................. 21 Understanding the needs of each stakeholder ......................... 23 CHAPTER 3: Architecting Your Enterprise ModelOps Capability ............................................................... 25 Understanding Model Life Cycles ..................................................... 26 Assigning Enterprise Ownership for ModelOps ............................. 29 Understanding Key Aspects of an Enterprise ModelOps Platform ............................................................................ 32 Identifying the key requirements................................................ 32 Answering the key questions ...................................................... 32 Integrating with Your Enterprise Processes and Systems ............. 34 Understanding and Meeting Regulatory and Compliance Requirements ..................................................................................... 35 iv ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Establishing ModelOps as the Foundation for Model Governance ............................................................................. 38 Visualizing the Results ....................................................................... 39 CHAPTER 4: Putting ModelOps into Action ......................................... 41 Benchmarking Your Place in the AI Journey.................................... 41 Choosing Where to Start ................................................................... 42 Learning from Real-WorldUse Cases .............................................. 43 Achieving straight-through processing ...................................... 43 Reducing fraud and bootstrapping ModelOps ......................... 44 Optimizing bond trading with AI ................................................. 45 CHAPTER 5: Ten Things to Know about ModelOps ....................... 49 Models Are Automating Decisions at Unprecedented Scale ........ 49 Models Are Among an Enterprise’s Most Valuable Assets ............ 50 Model Governance Is a Make-or-Break Issue ................................. 50 Ineffective Model Operations Is the Leading Cause of Failed AI Initiatives ......................................................................... 50 Treating Models Like Conventional Software Leads to Trouble ............................................................................................ 51 Know Where Your Models Are and What They Are Doing ............................................................................................. 51 Model Development Is a Business Unit Function; ModelOps Is an Enterprise Function ................................................ 51 Keeping ModelOps Separate from Data Science Makes Both Better .......................................................................................... 52 Good ModelOps Prevents Shadow IT .............................................. 52 Every Journey Starts with the First Step .......................................... 53 Introduction 1 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Introduction There’s never been a more exciting time for artificial intelli-gence (AI) technology. After decades of unfulfilled dreams, AI has moved solidly into the mainstream, and organiza- tions of all types are betting big on AI’s transformational power. But many organizations have struggled to see returns on their investments in AI, and worse, are seeing themselves falling behind others who seem to have cracked the code. As many have found, the problem isn’t so much in figuring out how to turn data into models that demonstrate the ability to create value but rather in getting those models out of development and into production where they can actually deliver value, and even more importantly, making sure that their models don’t bear risks that can damage or even sink the ship. About This Book This book explains an enterprise-level operational discipline called ModelOps, which has emerged as a key to unlocking the power of AI. ModelOps is a new enterprise capability that integrates and automates all the business, technical, and compliance stakeholders and activities across the organization to ensure that AI models — and all types of models — are governed, operated efficiently, and monitored continuously, producing value while remaining com- pliant. Because ModelOps is new, many organizations aren’t fully aware of what it does, how to do it well, and where it fits in the organization. But many are at least coming to the realization that ModelOps has become a must-have for organizations that will survive and thrive in the coming model-driven era. ModelOps For Dummies, ModelOp Special Edition, consists of five chapters that explore the following: » How models have evolved, why AI models pose significant new challenges, and why ModelOps is a critical capability for enterprises (Chapter 1) » The key requirements and stakeholders for ModelOps and how to structure ModelOps as an enterprise capability (Chapter 2) 2 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. » Implementing the most effective ModelOps capability (Chapter 3) » How to assess the maturity of your AI initiatives and when and where to start your ModelOps journey, with examples from successful organizations that have implemented ModelOps (Chapter 4) » Ten key fun facts about ModelOps (Chapter 5) Foolish Assumptions I made some assumptions about you, the reader, when I wrote this book. Mainly, I assume the following: » You have a stake in the success of your organization’s AI initiatives and work in one of the following: • A business unit that wants to unlock the power of AI • An operational team such as DataOps, ITOps, or DevOps • Risk management and compliance • A C-level executive with accountability to the board » You’re past the point of deciding if AI is important. You’ve done pilot projects and proven that you can generate significant value from automating decisions using AI and other types of models. Now you’re ready to scale up. » You’ve seen the challenges with operationalizing AI models. You know you’re missing out on value because it’s taking too long to get models deployed in production. And you’re becoming aware of the significant risks associated with industry regulations and consumer expectations regarding the use of AI in decisions that impact people’s lives. » You’re asking or being asked questions and not getting good answers. How many models do we have in produc- tion? Where are they running? Are they generating value? What’s the return on investment (ROI)? What’s our exposure? Do we have visibility and control over all of our model-driven initiatives? Don’t be afraid to become your organization’s expert in ModelOps! ModelOps by definition tightly integrates a variety of complex Introduction 3 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. and mature enterprise and business unit functions, including the following: » Business analysis » Data science » Enterprise digital architecture and strategy » DataOps » IT » Digital security » Risk » Business intelligence » DevOps » Corporate governance While you may have a background and detailed experience in one or two of these disciplines, most readers won’t have com- plete depth and experience in all the required disciplines that come together to fulfill a mature, capstone ModelOps capability. As you use this book to gain a full understanding of ModelOps, engage the experts, early and often, in your organization who are responsible for various existing capabilities that come together with ModelOps. Very quickly you can become your organization’s expert in ModelOps and gain a much fuller appreciation for the depth and complexity of all the disciplines necessary to ensure that your organization has a world class Enterprise AI capability. Remember, the capstone of ModelOps becomes the foundation for Enterprise AI. Icons Used in This Book Throughout this book, you see icons in the margins that draw your attention to certain kinds of information. Here’s what the icons mean. This book is a reference, but some nuggets of information are so important that you should commit them to your memory. With this content, I use the Remember icon. 4 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. The Tip icon indicates information that saves you time or money or just makes your life a little easier. The Warning icon alerts you to issues in ModelOps that could cause you a headache. I give you this information so you can avoid it at all cost. Sometimes I like to include statistical information or other pieces of information that may seem technical to some folks. When I do that, I include the Technical Stuff icon. Beyond the Book This book focuses on the high-level concepts regarding the role of ModelOps, how to architect an effective ModelOps platform, and how to structure the capability within your organization. If you want even more information, check out the following resources: » State of ModelOps2021: This report summarizes perspec- tives on the state of ModelOps from senior executives in large, global enterprises. For more information, visit www. modelop.com/wp-content/uploads/2021/04/State-of- ModelOps-2021.pdf. » 4 Steps to Successful Model Operations: This guide walks you through four steps that any organization can take to successfully operationalize AI and machine learning (ML) or any other type of model using ModelOps best practices. Head to www.modelop.com/wp-content/uploads/ 2021/03/modelop_ebook_4-Steps-1.pdf for more info. » ModelOp technical education: This series of videos includes master classes for ModelOps and the ModelOp Center platform. You take deep dives into a range of subjects, including how to manage AI/ML model risk; how to build a model life cycle with automated monitoring, remedia- tions, and retraining; how to create model life cycles that measure and monitor bias for AI/ML models in production; how to report on model revenue contribution; and more. To start watching, visit www.modelop.com/learning. https://www.modelop.com/wp-content/uploads/2021/04/State-of-ModelOps-2021.pdf https://www.modelop.com/wp-content/uploads/2021/04/State-of-ModelOps-2021.pdf https://www.modelop.com/wp-content/uploads/2021/04/State-of-ModelOps-2021.pdf http://www.modelop.com/wp-content/uploads/2021/03/modelop_ebook_4-Steps-1.pdf http://www.modelop.com/wp-content/uploads/2021/03/modelop_ebook_4-Steps-1.pdf https://www.modelop.com/learning/ Introduction 5 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. » Events and webinars: This page shows upcoming events and also has archives of past events, including fireside chats with industry practitioners, panel discussions, and the 2021 ModelOps Summit. Visit www.modelop.com/events. » The ModelOps Saga: This short video takes a comical look at critical C-level concerns with AI and how ModelOps is key to addressing them. Visit bit.ly/ModelOpsSaga-YouTube. » Stu Bailey’s insights on Gartner Market Guide for AI Trust, Risk, and Security Management: This video shares key highlights from the first Gartner market guide that offers some useful perspectives on the topic of AI trust and risk and security management, and gives you a list of representa- tive vendors, including ModelOp for the ModelOps pillar. Watch the video at www.linkedin.com/pulse/gartner- market-guide-ai-trust-risk-security-stu-bailey. https://www.modelop.com/events/ https://bit.ly/ModelOpsSaga-YouTube https://www.linkedin.com/pulse/gartner-market-guide-ai-trust-risk-security-stu-bailey https://www.linkedin.com/pulse/gartner-market-guide-ai-trust-risk-security-stu-bailey CHAPTER 1 Realizing that Models are Eating the World 7 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Chapter 1 IN THIS CHAPTER » Recognizing how models have evolved » Understanding why AI models are different from conventional software » Seeing the approaching AI iceberg » Framing ModelOps for the CEO and key execs Realizing that Models are Eating the World In 2011, noted venture capitalist Marc Andreesen famously observed that “software is eating the world.” History proved him right. Low-cost computing in the cloud and pervasive con- nectivity have enabled entire industries to be transformed by software. Today, an even greater transformation is underway driven by special kinds of software called models. By leveraging advances in artificial intelligence (AI) technologies and the vast pools of data now available in most organizations, models are playing a lead- ing role in transforming companies and industries. Models have powered companies like YouTube, Netflix, and, more recently, TikTok to extraordinary heights. But these well-known exam- ples are barely the start of a phenomenon that’s deepening and spreading across all aspects of our lives. In this new era, one can say that “models are eating the world.” Models aren’t new and have been used for decades in many indus- tries, primarily to assist human decision making. But something new is happening: Models have become much more powerful and are increasingly being used to actually make decisions automati- cally without human intervention. This has profound implications 8 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. because models, just like people, have to be accountable for the decision they make. While many organizations are making huge investments to develop AI models, few are able to deploy, manage, and govern them at scale. AI models have unique requirements, and as they move from business unit (BU) data science teams into produc- tion, they expose big gaps in most organizations’ operational capabilities. Even those enterprises that have been using conven- tional models in their businesses for years are being challenged to operationalize today’s more complex models. Many organiza- tions find that it can take 6 to 12 months to get a model that’s deemed “ready” deployed into production and generating value for use-cases such as detecting fraud, deciding prices, or opti- mizing manufacturing machinery. Of even greater concern, most organizations don’t have enterprise-level visibility into which models are in use in the business, how they’re performing, or if they’re in compliance. With the number of use cases for models skyrocketing, the rate of model development accelerating, and the attention of regulators growing, organizations are realizing that their success will be heavily dependent on their abilities to oper- ationalize and govern models at enterprise scale. In this chapter, you discover how models have evolved, under- stand why AI models pose significant new challenges, and learn why ModelOps is a critical capability for enterprises that seek to maximize the power of AI while managing the risks. Tracing the Evolution of Models Models are software artifacts that drive decisions based on data. For the purposes of this book and discussion, I define models as digital representations of processes or systems. Given a set of data inputs, a model produces an output, usually a value or set of val- ues, that’s then used to dictate decisions and actions for the busi- ness use case. For example, a model might output, “yes” a person will receive a loan, or “$1,500” is the amount a credit line will be increased, or “29, 12, 4” are the inputs that a machine operator will enter into the factory equipment at this time. Many enterprises have employed models for decades to add speed, accuracy, and consistency to human decision making. CHAPTER 1 Realizing that Models are Eating the World 9 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Some conventional model types that have been in use for many years include » Rules-based models: A typical example is an if-then-else decision tree. » Algorithmic models: These encode mathematical opera- tions, such as linear regression. Rules-based and algorithmic models are effective when the underlying processes and systems that they represent can be explicitly described and when the outputs for a given set of inputs are deterministic — that is, the same every time. But much of the universe is neither easy to describe nor orderly, and there- fore deterministic models can become unwieldy for encoding the behavior of anything other than the most straightforward pro- cesses and systems. As an example, consider trying to write a set of explicit instructions for how to recognize a picture of a cat or how to drive an autonomous car. Another class of models, known as stochastic or statistical models, uses probabilities and statistics to capturethe randomness found in the real world. Creating these models involves fitting the data observed in real systems to probability distributions, which are then used to predict the outcomes for new data inputs. Stochastic models have also been in use for many years. One common exam- ple is the actuarial tables used by insurance companies to predict life spans and calculate premiums. The newer classes of AI models that are generating so much excitement include the following: » Machine learning (ML) models: This category covers a broad range of stochastic models that are, in essence, algorithms created by training rather than by programming. » Natural language processing (NLP) models: NLP models are specialized ML models that incorporate the rules of language along with ML to enable software programs to communicate with people using writing or speech that mimics human interactions. ML represents a major breakthrough in AI technology. With ML, it isn’t necessary to explicitly identify and code the complex sta- tistical relationships between variables. Instead, using the tools 10 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. and techniques of data science, models are created by highly skilled data scientists using a process called training, in which pre-selected data sets are presented to the model, the outputs are compared with known results, and the algorithm is tweaked until it produces accurate results. For example, an image recognition model may be fed with data from pictures of cats labeled as “cat,” and other animals labeled appropriately. With this approach, ML models have been trained to recognize cats — and just about everything else for which a training data set can be created. Many types of ML models exist, and their applications go far beyond image recognition and other so-called classification use cases to include the following examples: » Recommendation engines that choose the next item in your social media feed or video playlist, or suggest a product to purchase » Diagnostic models that predict equipment failures or the onset of disease » Financial models that drive stock and asset trades » Behavioral models that predict customer retention or churn In practice, many applications use composite models, which link together the outputs and inputs of multiple AI and conventional model types to automate complex decisions. Understanding the Differences Between Models and Software Software automates processes. Models automate decisions. Of course, most models are software in the sense that they’re implemented on computers by executing a series of instructions. The outputs of models, known as scores or inferences, are typi- cally consumed by software applications that then take actions based on the model’s output. Initially, model outputs were used to aid humans making the actual decisions, but increasingly, model-driven applications are using a fully automated decision- ing process that minimizes and even bypasses human interven- tion. The rapid trend toward fully automated decisioning in large CHAPTER 1 Realizing that Models are Eating the World 11 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. and complex businesses, a phenomenon called Enterprise AI, is powerful and transformative but also raises significant issues because models are different from conventional software in many key ways: » Models encode an organization’s most valuable intellec- tual property, which includes the behaviors of custom- ers, employees, suppliers, products, partners, and markets. While much of the enterprise software that was previously proprietary has been commoditized, many of the most valuable models don’t readily commoditize. This makes models, even more than conventional software, critical corporate assets that require extremely effective curation and management. » ML models don’t execute deterministic rules. Their operation is often opaque to some degree; for example, with some types of ML models, it isn’t possible to determine precisely how or why a model generated a particular output. This issue has many ramifications, especially as models are increasingly subject to regulations to ensure their efficacy and fairness. » Models require direct accountability to the business organizations that employ them. Because the decisions made by models have direct impacts on the top and bottom lines, business owners need real-time visibility and control over models in production to a much greater degree than is typical with conventional software applications. » Models require significant governance and oversight to limit organizational exposure and risks. The decisions that models automate can significantly impact people’s lives. Examples include whether a person qualifies for a loan, a job interview, a raise, or a medical procedure, or if an obstacle in the road is a cardboard box or a person. In some industries, like banking and insurance, models are already subject to government regulations, and many countries are working to implement broad-based regulation of AI models. » Models require strict monitoring to ensure that they’re producing valid inferences. If the data being fed to the model in production reflects a different world than what was reflected in the training data, the model will produce bad inferences and cause bad decisions. For example, without appropriate monitoring of a municipal bond pricing model, 12 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. an error in market reporting data from an external source or an arithmetical error in data preparation of the input to a model may cause a pricing model to consume data well outside of the allowable range and either fail outright at a critical time or — worse — produce an output that’s outside of corporate tolerances, causing devastating losses similar to those caused by a rogue trader. » Unlike conventional software, models go stale. Depending on the use case and how fast behaviors can change, a model may need to be retrained annually, quarterly, monthly, weekly, daily, or even hourly. In situa- tions where a significant, rapid change occurs in the environment — the COVID-19 pandemic being a prime example — ML models can rapidly lose their predictive efficacy. Treating models as if they’re conventional software slows model deployment, lowers their efficacy, increases costs, and exposes the organization to increased risk. Seeing the Tip of the AI-Iceberg It’s quite common today for organizations to foresee and plan for a world in which hundreds or thousands of models are making most or all the actual decisions. But even that level of scale may severely underestimate the scope of the coming challenge. Imag- ine what happens when any app, even any spreadsheet, has the ability to create models that need to be monitored, managed, and, in many cases, regulated. In that sense, the challenges today are just the tip of a looming AI Iceberg. Even with a relatively small number of models in production, few organizations have achieved excellence in their abilities to gov- ern, deploy, monitor, and continuously manage them. In fact, many organizations don’t actually know which models, or even how many, are driving which decisions. This is especially con- cerning for several reasons: » Data science tools are becoming more powerful. Data scientists are able to create more models in less time. » More people will gain the power to create models. New tools will enable people without deep technical backgrounds CHAPTER 1 Realizing that Models are Eating the World 13 These materialsare © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. in AI — so-called citizen data scientists — to further add to the flood of models. » Models may gain the power to create models. In a concept called generative AI, models can create new models. » Mainstream applications will gain the ability to create models. Business analytics applications and even spread- sheets may include the ability to generate ML models. » The rapid proliferation of models is contributing to “AI-Driven Shadow IT.” As model development outpaces deployment, BUs and departments are using Shadow IT to get their models into production — in many cases bypassing corporate security and governance controls. If the IT, security, and compliance organizations don’t have vis- ibility to or control over models, they can’t protect the enterprise from their associated risks. Framing ModelOps for the Exec Team and CEO Models have played important roles for years in many companies and industries, but in the coming AI-driven era, models may be the most valuable of all corporate assets. To be successful, organizations need to achieve excellence in their ability to gov- ern, deploy, and manage models at scale. Models are different from conventional software in many significant ways; therefore, the capabilities that organizations have developed for managing software can’t simply be extended to support models. A new capability called ModelOps is emerging to address the unique requirements of governing, operationaliz- ing and managing AI models, and all decisioning assets across the enterprise, at scale. ModelOps is a foundational capability for Enterprise AI. ModelOps ensures that data science investments are operational, working properly, generating business value, and being held accountable. Figure 1-1 shows you an example of an executive-level dashboard of the business, operational, and compliance status of all AI ini- tiatives across an enterprise. This screenshot helps you visualize 14 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. the power of a mature, enterprise ModelOps capability. It displays the cumulative value produced by selected models in produc- tion, which is key to determining the ROI for AI investments. The dashboard also highlights operational and compliance metrics that may be out of threshold or nearing threshold, which enables functional teams and senior executives to identify issues quickly and drive them to resolution. Models are very specific to particular use cases and as such are typically created or sourced at the BU level. However, models have implications for business performance, resource use, and risk that are enterprise-level concerns. ModelOps is therefore a corporate-level capability that ensures all models, regardless of where they’re created or where they execute, are deployed, mon- itored, managed, and governed appropriately. Like other major corporate functions such as IT, Finance, and HR, ModelOps is an enterprise-accountable function. For a deeper look at the key stakeholders and their needs, check out Chapter 2. A mature ModelOps capability enables end-to-end governance of all AI and model-driven initiatives. FIGURE 1-1: An executive-level dashboard. CHAPTER 2 Understanding the Role Played by ModelOps in Enterprise AI 15 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Chapter 2 IN THIS CHAPTER » Getting to know the key requirements for ModelOps » Seeing models as enterprise assets » Delineating the differences between ModelOps and MLOps » Identifying the primary stakeholders Understanding the Role Played by ModelOps in Enterprise AI The first steps in developing an enterprise ModelOps capa-bility are to detail its requirements and determine how to organize and manage the effort. Doing so can be harder than expected. Discussions about ModelOps often conjure an image of the proverbial elephant and seven blind men, each asserting that the particular part of the elephant that he holds — ear, tusk, tail, trunk, foot, and so on — represents the entire ani- mal. In a similar way, each of the various groups that have a stake in production artificial intelligence (AI) models have particular needs driven by their functional roles and perspectives. A further complication stems from the tension between the need for speed and flexibility at the business-unit (BU) level and the need for accountability at the enterprise level. A further challenge is that, in most organizations today, no single group has responsibility for models as assets or ModelOps as an enterprise-wide capabil- ity. As a result, many enterprises lack a clear roadmap for imple- menting ModelOps and also struggle to determine how to structure it organizationally. Addressing these issues is the critical first step in the ModelOps journey. 16 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. In this chapter, you discover the key requirements for ModelOps, identify the stakeholders and their needs, and see how to struc- ture ModelOps as an enterprise capability. Knowing the Key Requirements for ModelOps ModelOps is the discipline by which enterprises scale and gov- ern their AI initiatives. A well-designed and managed ModelOps capability enables an enterprise to do the following: » Provide visibility and accountability for all model-driven initiatives for all stakeholders. » Manage and mitigate model risks. » Automate and orchestrate the policies and processes that keep models performant and compliant. » Get production-ready models of all types deployed into applications and delivering value as quickly as possible. » Ensure that all models are meeting their statistical, opera- tional, business, and compliance key performance indicators (KPIs). It’s important to note what’s not included in the list of key ModelOps requirements: Specifically, model creation isn’t a part of ModelOps. Of course, data scientists are key stakeholders in ModelOps; however, the process of model development isn’t a part of ModelOps and, is generally a BU-level concern. For this reason, rather than standardizing on a single data science platform, a variety of data science tools and platforms are being used to make models in most organizations. ModelOps is separate and distinct from data science. The primary objective of data science is to create models in response to specific business requirements. The primary objective of ModelOps is to scale and govern AI initiatives across the enterprise. ModelOps starts when a business use case is defined and con- tinues until a model is retired. ModelOps envelops but doesn’t include model development. This process is shown in Figure 2-1. CHAPTER 2 Understanding the Role Played by ModelOps in Enterprise AI 17 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Separating ModelOps as a distinct discipline from data science is important for several reasons: » Data scientists have unique skillsets for building models. They typically have years of training in their field and often hold PhD degrees. They generally have little or no experi- ence with or interest in operating an enterprise production environment. Using data scientists to do ModelOps is like using a Formula 1 car engineer to manage the logistics for moving the team and equipment from race to race. » Models bear enterprise-level risks. While models are typically created for a particular BU, they need to be FIGURE 2-1: ModelOps encompasses all elements of themodel life cycle (MLC) pre- and post-model development. 18 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. accountable at the enterprise level because of the scale of the business impact they provide, the resources they consume, and the risks they expose. » Models are increasingly subject to internal compliance controls and external regulations; therefore, model governance is a core pillar of ModelOps. For model compliance controls and audits to be effective, they need to be implemented by a group distinct from the group that developed the model. Indeed, in regulated industries, it’s required that the group responsible for compliance is separate from the group being audited. Otherwise, it’s like having students grade their own papers. Recognizing that Models Are Enterprise Assets Models are developed to address specific business needs, and these needs frequently originate within a particular BU. In that sense, models may be thought of as BU assets. But models are also enterprise assets in the following sense: » The decisions that models drive at the BU level expose the organization to corporate-level brand risks, external regula- tory compliance risks, and corporate-level financial risks. » The infrastructure in which models execute, such as a data center, private cloud, or public cloud, are enterprise assets managed by the ITOps team. » The data consumed by models is provided by the DataOps team, which is usually structured as a central, enterprise resource. » Models expose the organization to enterprise-level risks. For example, a model that makes financial decisions can lose millions if the model isn’t monitored and maintained properly. And as concerns about bias and fairness in AI gain broader attention, organizations face the possibility of significant brand damage if they’re found to employ models that don’t meet ethics standards. This is a key reason why risk management is nearly always an enterprise-level function. CHAPTER 2 Understanding the Role Played by ModelOps in Enterprise AI 19 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. This interplay between models as highly local to the BU and yet also enterprise assets often creates tensions within organiza- tions that are trying to scale their AI initiatives. BUs are hiring data scientists and pressing them to develop and deploy models as quickly as possible. Data science tools are evolving and chang- ing rapidly, and data scientists want the freedom to use the most appropriate techniques and tools to address each business chal- lenge. Understandably then, data scientists and their business owners are concerned that a centralized, corporate ModelOps function that’s not accountable to the BU will be unresponsive and will impose restrictions and bulky processes that limit inno- vation and slow them down. The concerns around locating ModelOps as a centralized, enterprise- level capability are valid and must be addressed in order for ModelOps to deliver on its role in scaling and governing AI initiatives. (Check out Chapter 3 to avoid the pitfalls that can make ModelOps a hindrance rather than a help.) However, in light of the substantial opportunities and risks associated with mod- els, most organizations treat models as enterprise-accountable assets, and this is a key pillar of any ModelOps strategy. The first step in untangling the ModelOps knot is to recognize that models are enterprise assets in the same way that cash, employees, and data are enterprise assets. This means that key operational questions regarding models — including how many are in production, how they’re contributing to the business, and if they’re in compliance — are C-level executive concerns. Understanding the Differences between ModelOps and MLOps The term MLOps is sometimes used interchangeably with ModelOps; however, they’re distinct disciplines that serve differ- ent purposes and constituencies. Confusing one with the other is a detriment to both and to the enterprise as a whole. 20 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. The term MLOps stands for Machine Learning Operations, and as the name suggests it’s limited to ML models. This is the first key dis- tinction between MLOps and ModelOps because the latter encom- passes all types of models, not just ML models. But the differences only begin there. The primary purpose of MLOps is to support data scientists during the model development process by automating those parts of the development cycle, specifically algorithm selection and training, that involve running the model against data sets and analyzing the results. However, MLOps has taken on additional significance and scope in recent years in response to the problem of model operationalization. Many organizations have found that over 50 percent of the mod- els they develop never get into production. They also report that it can take as much as six months or a year for a model to be fully deployed. Additionally, once in production, models may not be appropriately monitored, managed, and governed. In response, data science and machine learning (DS/ML) platform and cloud AI providers have extended their systems with additional deploy- ment, monitoring, and, in some cases, governance features under the category of MLOps. The challenge with using MLOps tools for ModelOps, beyond the fact that it only encompasses ML models, is that the needs of data scientists are vastly different from the core constituencies for ModelOps, which include the chief information officer, chief financial officer, vice president of IT, and the chief risk officer. Data scientists are primarily concerned with creating high-value models as fast as possible. To do so they need to be able make changes and try new approaches with maximum speed and flex- ibility. However, managing production operations requires strict adherence to processes and procedures. Approvals, sign-offs, and audits, which are critical for operating production applications at scale, are unwelcome in the development process. So there’s a fundamental conflict between making a great MLOps platform and a great ModelOps platform. Table 2-1 shows you the key differences between MLOps and ModelOps. CHAPTER 2 Understanding the Role Played by ModelOps in Enterprise AI 21 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Introducing the Enterprise AI Team Enterprise AI is a team sport that requires a carefully orchestrated interplay among multiple groups and consideration of their needs. This section explains both. Identifying the key stakeholders The key stakeholders in your organization include the following: » The BU: Every model serves a specific business need, such as increasing revenue, reducing cost, increasing customer satisfaction, and so on. BUs often sponsor development of models and are ultimately accountable for demonstrating the return on investment (ROI) for the models’ development and operating costs. TABLE 2-1 The Differences between ModelOps and MLOps ModelOps MLOps What is it? An enterprise capability that provides governance and operations for models in production A feature in data science platforms that provides rapid experimentation and deployment of ML models during the data science process Who owns it? CIO/IT Data scientists within the line of business Primary users Enterprise risk, enterprise IT, or line of business operations Data scientists Primary capabilities Enterprise-wide product model inventory; complete model life cycleautomation; 360-degree enterprise visibility, monitoring, auditability for all models in production Tight integration with specific data science platform; rapid deployment of models for experimentation and testing during model development; data science performance focused monitoring integrated with specific data science platforms 22 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. » Data scientists: These folks are the model builders. They’re highly skilled people with deep backgrounds in data analytics, statistics, and AI techniques such as ML. Data scientists are often embedded in BUs to be closer to the business problems that they’re addressing. » DataOps: Data is the life blood of models. Because data is a corporate asset, DataOps is generally an enterprise capabil- ity under the chief data officer. The DataOps team collects, processes, curates, protects, and feeds data to data scientists at the BU level during model creation and to the ITOps team back at the enterprise level for models in production. » DevOps: The DevOps team develops and operates the applications that consume the models’ inferences and take corresponding actions, such as placing an ad in a user’s newsfeed, recommending a product, or approving an insurance claim. Enterprise-level DevOps processes such as containerization and service-level unit testing are often critical and mandatory procedures required to get various models into production. » Central Technology/IT/ITOps: This team is responsible for • Enterprise architecture • Organization-wide digital security • Enterprise systems — such as databases and identity management • The infrastructure on which the models and applications run, whether in the company’s data centers, in private or public clouds, in end-use devices such as smartphones or Internet of Things (IoT) products, or in some combination » Compliance: Also called risk management, the compliance team is charged with protecting the organization against financial and reputational risks by ensuring that models operate within internal guidelines and external regulations. Figure 2-2 shows you these key groups that have a role in the ModelOps. CHAPTER 2 Understanding the Role Played by ModelOps in Enterprise AI 23 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Understanding the needs of each stakeholder Each team has its own perspective, or context, through which they view models: » The BU is concerned with understanding how the model is contributing to its intended business outcome, such as higher sales or reduced customer churn, and if the model is generating a favorable ROI. » Data scientists are concerned with how the model is performing technically and if it’s delivering valid statistical inferences. » DataOps views the model as a data consumer that needs data of a particular type, quality, volume, and speed. » The DevOps team sees the model as a software component with unique requirements, such as periodic retraining, that are different from conventional software. FIGURE 2-2: ModelOps requires participation and coordination among a diverse set of enterprise stakeholders. 24 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. » The enterprise technology team sees the model as a software asset that requires a tightly controlled operating environment and an associated allocation of storage, compute, and networking resources sufficient to meet performance targets. They also see ModelOps platforms as highly integrated systems that must integrate with existing systems and align with present and future state enterprise architectures. » The compliance team sees the model as a risk-bearing asset that must be proven to operate within company standards and regulatory guidelines. An effective ModelOps capability provides all stakeholders with the degree of visibility and control of models appropriate to their roles. In Chapter 3, you see how to architect your enterprise ModelOps capability so it meets the requirements of the entire organization and avoids the key pitfalls. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 25 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Chapter 3 IN THIS CHAPTER » Defining model life cycles » Assigning ownership for ModelOps » Identifying the key requirements for an enterprise ModelOps platform » Working with your enterprise processes and systems » Addressing regulatory and compliance requirements » Looking at the foundation for model governance » Seeing the end results Architecting Your Enterprise ModelOps Capability Companies that were “born digital,” with businesses built from the ground up around software and data, are often structured in a way that offers a relatively straight path to becoming model-driven. But non-digital native companies, espe- cially in regulated industries, find it much more challenging to operationalize their data science investments, not because of technical challenges but because of a lack of clear organizing principles regarding how ModelOps should be structured, which groups should fund and manage it, and how it should relate to data science at the business-unit (BU) level and all the other enterprise-level functions that it touches. 26 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. In this chapter, you see how to implement the most effective ModelOps capability by architecting it as an independent, enter- prise function accountable at the highest level of the company and with models at the center. Understanding Model Life Cycles Operating a model in production requires a carefully orches- trated set of processes that touch multiple teams and systems. For example, once a model is declared “ready for deployment” by data scientists, a number of steps need to take place: 1. Integrate with code repository, ticketing, risk manage- ment, and other enterprise systems. 2. Prepare a runtime image that can be operated at scale by the ITOps team in the target execution environment. 3. Deploy into a quality assurance (QA) runtime environ- ment for testing and validation. 4. Verify that the model has passed checks for statistical accuracy and compliance with standards and regulations. 5. Complete security scans. 6. Instrument the model for monitoring. 7. Integrate with production data pipelines. 8. Approvers sign-off to verify that all steps have been executed. After the model is in production, it must be monitored continu- ously and measured against technical, business, and regulatory targets. Variations from key performance indicators (KPIs) must be flagged and trigger remediation processes that are driven to resolution. For example, ML models require periodic retraining to maintain efficacy. For high-value models, data science teams may continually produce “challenger” models that will replace the “champion” model in production if the challenger demon- strates better results. Computing resources may need to be scaled in order to meet operating KPIs for throughput and latency. Mod- els must also be reviewed against ethical standards for bias and fairness. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 27 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. These activities span multiple teams including the BU business owners, data scientists, DataOps,DevOps, ITOps, and compliance, and all actions must be exhaustively documented to satisfy inter- nal and external audits. Any missed steps along the way can result in diminished or harmful business results and can also expose the business to liabilities. Without automation, the complexity of these tasks won’t scale with the desired increase in the number of models making decisions in the organization. The key tool used for managing the complexities of models in production is the model life cycle (MLC), which is a blueprint that captures the steps required to get a model in production and keep it operating within targets. It also codifies the responsibilities of each team and identifies the hand-offs between them. An MLC defines the requirements and processes for operation- alizing a model at the enterprise level. It includes detailed pro- cess workflows with well-defined steps for operating, governing, and maintaining the model throughout its post-development life cycle, until it’s retired, and ensures that all these steps are auditable. A typical MLC can have hundreds of steps and parameters. A powerful way to capture and visualize these steps is using the flowchart format used for business process management notation (BPMN), shown in Figure 3-1. FIGURE 3-1: A subsection of an MLC showing the steps involved with model validation and approval. 28 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Figure 3-1 captures just a small portion of a complete MLC — in this case, a section focused on model risk management (MRM). In practice, MLCs have multiple sections that cover all the different aspects of the model’s life cycle, including the following: » Use-case definition and documentation initiation processes: Captures the business justification for spending resources to develop models and identifies the enterprise risk classifications that the model or models for the use case will carry through their life cycle, consequently dictating any appropriate downstream model risk processes for the models; associates the profit and loss (P&L) context appro- priate for assessing model return on investment (ROI) » Model registration processes: Captures all artifacts of a model, including code, training data, production runtime requirements, operational data requirements, approvals, and so on in a production model inventory » MRM processes: Captures all regulatory requirements for the model and implements the periodic testing necessary to demonstrate compliance, collects all related data, and generates reports to fulfill audit requirements » Operationalization processes: Orchestrates the delivery of model runtimes into the execution environment, drives and tracks change management, and provides the interfaces to supporting enterprise IT service management systems » Monitoring processes: Ensures that models are performing optimally across business, technical, operational, and compliance KPIs; triggers remediations as necessary; includes champion/challenger testing, data and concept drift monitoring, model retraining, interpretability, fairness testing, and so on The various processes that models must journey through in their lifetime have unique MLCs. In fact, the same model deployed in multiple applications may traverse different MLCs for each use case depending on the business, technical, and compliance condi- tions that apply. The key is that the model — not the data, appli- cation, execution environment, or anything else — is always at the center of every MLC. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 29 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Developing MLCs requires a unique blend of skills covering a wide range of disciplines, including business management, data sci- ence, IT operations, and compliance. This requirement has led to the development of a new role: the Enterprise AI architect. This person works with all stakeholders to develop and document appropriate MLCs for each model and also architects the pro- cesses and tooling used to automate the MLCs and integrate them with the organization’s existing processes and tool stack. Assigning Enterprise Ownership for ModelOps In many enterprises, key questions remain as to which part of the organization has responsibility, and budget, for ModelOps. AI initiatives frequently start with experimentation in a corporate AI Center of Excellence and then move to one or more BUs that see potential to use AI to address specific business challenges or opportunities. After a successful pilot project, there’s often great excitement, and pressure, to get the new models into production and producing value. It’s at this point where things can start to go wrong. If the use case, risk, and target business justification aren’t captured prior to the start of data science activity then the post development problems are dramatically amplified. In some cases, models are released by the data science team to the operations teams with the expectation that they’ll be put into production using the same processes used for conventional soft- ware. In practice, this approach often doesn’t work well because the requirements for operationalizing models are more complex than those for conventional software. The existing operational teams — DataOps, DevOps, ITOps, compliance, and so on — don’t have the scope or expertise to address all the requirements for model operationalization. They also don’t spontaneously organize themselves into cross-functional groups with clearly defined processes and associated tooling to manage the processes. This lack of clear roles and accountability contributes to the long delays and low success rates experienced with many AI initia- tives and is also responsible for the rise of AI-driven Shadow IT, 30 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. in which individual BUs take model operationalization into their own hands. Read the sidebar “Avoiding AI-driven Shadow IT” for more information. In some cases, the degree of corporate risk or the lack of clear business justification isn’t exposed until after a model is in pro- duction, thereby compounding the impacts of any failures in model productionization and ongoing operation. In the worst case, a model is deemed to be a liability rather than an asset. In that unfortunate case, key stakeholders may find themselves making statements like “If everyone understood the business risk of this model failing, we would have never authorized the data science work to develop it.” So who owns ModelOps? The most effective structure for ModelOps in the enterprise is assigning it under the chief information offi- cer (CIO). Figure 3-2 shows a high-level view of this structure. AVOIDING AI-DRIVEN SHADOW IT Model operationalization challenges reduce the value derived from AI initiatives and put pressure on BUs to justify their data science invest- ments. In response, some BUs put models into production using the MLOps capabilities of data science platforms, which can be done rela- tively easily if models are deployed into a public cloud. The problem is that this activity can easily bypass the central IT, security, compliance and other organizations, resulting a kind of AI-driven Shadow IT. Further, the MLOps capabilities provided by model development plat- forms and hyperscale vendors are rarely comprehensive and don’t orchestrate full MLCs with enterprise-level visibility and governance. Using Shadow IT for model deployment is an understandable reaction to delays in getting models into production, but it adds significant risk to AIdeployments. The key to avoiding Shadow IT is to implement an effective, enterprise- level ModelOps capability that gives data scientists the freedom to innovate and solve problems with their preferred tools and doesn’t require them to manage production and compliance details. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 31 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Under the CIO are two new roles: » The Enterprise AI architect works across all stakeholders to define MLCs and also specifies and implements the tooling used to automate MLCs and integrate with the enterprise IT stack. The Enterprise AI architect understands the model in all its contexts: An asset that drives business value, con- sumes IT resources, and bears risk for the enterprise. Good candidates for the role are often those who have experience as Enterprise IT architects because they also require a deep understanding of IT systems as well as an ability to commu- nicate effectively with teams across the organization. » Model operators are the technical staff assigned to monitoring all models in production to ensure that any issues or bottlenecks are addressed quickly by the appropri- ate stakeholders. Good candidates often have experience in ITOps, SecOps, or other highly-responsive operational roles. Model operators are the primary users of ModelOps automation platforms. Elevating ModelOps to a corporate-level capability provides enterprise-level accountability for AI initiatives and provides the best structure for ensuring that all stakeholders stay coordinated and have the appropriate degree of visibility and control over their aspects of model operation and governance. FIGURE 3-2: A high-level view of ModelOps under the CIO. 32 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Understanding Key Aspects of an Enterprise ModelOps Platform An enterprise ModelOps platform must meet key requirements to enable an organization to answer key questions. I cover both in this section. Identifying the key requirements The term ModelOps platform refers to the software systems used to automate ModelOps. The key purposes of an enterprise ModelOps platform are to » Maintain the authoritative “source of truth” regarding everything about every model running in the business, from cradle to grave. » Provide the ability to define and automate MLCs. » Connect every model to its business value, business risk, and approval/compliance status. Answering the key questions The ModelOps platform enables stakeholders across the enter- prise to answer the following questions quickly and easily: » Which models are running in production? Where are they deployed? » How much value is each model bringing? Which resources is each model consuming? What is the ROI for each model? » Are models performing to operational targets? Are their results accurate? Do any need to be retrained or replaced? » Were all models tested and validated? Which tests were run, and who approved them? » Are any models not performing within compliance or thresholds? » Can we satisfy in an audit that all regulatory requirements have been met for all effected models? CHAPTER 3 Architecting Your Enterprise ModelOps Capability 33 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. To achieve its core purposes, an effective ModelOps platform should include all the following core elements: » A comprehensive and evergreen production model inven- tory, which is a database of all models in production and all their associated artifacts and metadata (code, execution requirements, training data, KPIs, performance logs, test results, changes, approvals, and so on) covering from model inception to retirement A model inventory is more than just a repository. Fully describing a model in all of its contexts requires a number of repositories — for example, a code repository that holds the model execution code, an artifact repository that holds the weights and coefficients associated with the model that were generated during training, and others. The model inventory includes pointers to all model artifacts and metadata in all repositories across the full MLC, from when the model was commissioned until after it’s retired. » A repository for storing, editing, and managing MLCs » A BPM engine for automating the execution and tracking of MLCs » A production runtime engine with full instrumentation for monitoring models in production, and interfaces to models that are delivered within a third-party runtime engine » Configurable dashboards for showing the real-time status of all models across statistical, performance, business, and compliance KPIs, individually and in aggregate » Interfaces to data science and machine learning (DS/ML) platforms and third-party model repositories to support easy import of models post creation » Interfaces to existing enterprise IT systems for identity and access management (IAM), code management, ticketing, analytics, and so on The relationship among these elements is shown in Figure 3-3. A well-architected ModelOps platform provides an authoritative source of truth for all data associated with all models used in the enterprise, regardless of where they’re sourced or executed. 34 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Integrating with Your Enterprise Processes and Systems The primary users of the ModelOps platform are the Enterprise AI architect, who defines MLCs, and model operators, for whom the ModelOps platform is their command center, providing full visi- bility and control for all models in the business. If the platform is architected and integrated properly, the other key stakeholders, such as Data Science, DataOps, ITOps, DevOps, and Compliance, generally don’t need hands-on access to the ModelOps platform, but instead they’re able to perform their roles within the context of existing enterprise tools. FIGURE 3-3: A well-architected ModelOps platform. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 35 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. For example, if a model operator is asked which models didn’t pass their data drift constraints and what happened to them when they failed (for example, any tickets that were automatically generated in systems such as Jira), they can use the ModelOps platform to accurately generate both the list of such models and exactly where they are in the remediation process. If the data scientist retrains or changes the model, the updated model is placed in the enterprise code repository, such as Github. Via integration with the ModelOps platform, the code changes trigger the MLC to execute additional steps, such as code scanning and testing, approvals, and release to ITOps for deployment in, say, a cloud execution environment. Each operational team is able to work within its existing tools, and the platform orchestrates and records all activity. A key way to ensure that the Enterprise ModelOps is embraced by all stakeholders is to support integrations with the tools that they already use. This approach eliminates the need to train most of the stakeholders on a new tool and greatly simplifies implemen- tation of the ModelOps platform. Understanding and Meeting Regulatory and Compliance Requirements Even before AI models started to see widespread use, MRM had been an established function in many companies, especially in industries like bankingand financial services. In the wake of the 2008 financial crisis, when it became clear that weaknesses in model governance created huge exposures for financial institu- tions, various United States regulatory bodies, such as the Fed- eral Reserve, FINRA, and the SEC, and their counterparts in other countries, began to issue increasingly stringent guidelines and regulations governing the use of models. A good example of regulations that impact models is Supervi- sion and Regulatory Letter SR 11-7 and its associated attachments issued by the United States Federal Reserve in 2011. Specific to the banking industry, SR 11-7 sets out comprehensive requirements and policies for how models should be developed, used, validated, and governed. As a result, MRM has become a core corporate 36 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. function with board-level visibility and authority in the financial sector. Regulatory authorities have levied significant penalties against organizations deemed to have inadequate governance. Some examples include » A major United States-based bank was fined $400 million by the Federal Reserve’s Office of the Controller of the Currency (OCC) for lack of controls, including around data analytics, and ordered to establish a new risk management function. » A European Union (EU)-based company paid a $240 million settlement due to errors in model code that were revealed but not corrected. Regulatory scrutiny of decisioning models is expanding well beyond financial services to cover all industries and a wider range of issues associated with their use. For example, models are being used and proposed for a dizzying variety of use cases, including predicting equipment failure, evaluating employees, diagnosing disease, piloting autonomous vehicles, and identifying crimi- nals. A good example is EU 2021, which proposes comprehensive requirements and accountability for models across a wide variety of contexts. See the nearby sidebar “Seeing the future of AI regu- lation” for more in-depth information. In addition to requirements dictated by government regulations, the marketplace also imposes requirements on organizations that use AI. Consumers increasingly demand that the companies they buy from employ business practices that are ethical and fair, and enterprises have had to respond. So whether responding to regu- latory fiat or market pressures, AI-driven enterprises will need to establish governance policies and processes regarding the models they use that address, at minimum, the following concerns: » Efficacy: Decisions driven by models that aren’t built or maintained properly can put individuals or whole companies at risk. Models must be developed properly and validated periodically to ensure that they’re robust and produce good results. » Transparency: In order to protect individuals and groups from unfair treatment, the decisions made by models need to be explainable and provably free from bias. CHAPTER 3 Architecting Your Enterprise ModelOps Capability 37 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. » Ethical use: Some potential uses of AI models can do significant harm. One common example is the use of models to do social scoring with the ultimate goal of restricting an individual’s access to products, places, or services. Another is using models to create deep fakes, which are AI-generated audio or video clips of people that are used to damage their reputations or subject them to extortion. Some proposed regulations explicitly limit or ban these kinds of use cases. SEEING THE FUTURE OF AI REGULATION An important regulation under development is EU 2021 — New Rules and Actions for Excellence and Trust in AI. This set of proposed regu- lations applies to AI systems produced and used in the EU as well as in non-EU countries. The rules focus on so-called “high-risk” AI sys- tems, which include a wide range of devices and services from machinery and elevators to medical devices and toys. Specific uses subject to the rules include • Biometric identification and categorization of natural persons • Management and operation of critical infrastructure • Education and vocational training • Employment • Law enforcement • Migration • Asylum and border control • Administration of justice and democratic processes The proposed penalties for failing to comply are severe, ranging from 2 to 6 percent of a company’s annual revenue. This penalty makes compliance a board-level concern for any affected organization. If EU 2021 is adopted in a form similar to the initial proposal, nearly all uses of AI models will fall under the regulations. 38 ModelOps For Dummies, ModelOp Special Edition These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Regulating the use of models is a global concern. Many key model regulations are in place or proposed in the following countries: » United States: U.S. SR 11-7 — requires MRM for all models in financial services; U.S. 2019 Proposal for Algorithmic Accountability Act » EU: EU 2021 — New Rules and Actions for Excellence and Trust in AI » Canada: Directive on Automated Decision making and Algorithmic Impact Assessment » Singapore: Model AI Governance Framework » United Kingdom: AI Public Private Forum » Mexico: 2018 — General Principles for AI Establishing ModelOps as the Foundation for Model Governance While the particulars may vary among different industries and use cases, the essentials of good model governance are fairly con- sistent and include the following: » Establishing clear policies regarding the standards that models must meet across all contexts, including business metrics, statistical metrics, internally generated compliance metrics, and external regulations » Extensively documenting the purpose for each model, its metrics, how it was developed, and how it needs to be deployed » Identifying all necessary approvals and approvers as the model moves from concept to development and into production » Capturing all artifacts and metadata associated with the model, including code, training data, test cases, and results » Logging all activities that happen with the model from the time of release to production through retirement, including deviations from KPIs, remediations such as code changes or retraining, and all approvals that took place at each step CHAPTER 3 Architecting Your Enterprise ModelOps Capability 39 These materials are © 2022 John Wiley & Sons, Inc. Any dissemination, distribution, or unauthorized use is strictly prohibited. Most regulatory bodies require that the personnel who test and validate models must be separate from those who develop mod- els. This generally means models can’t be validated by the by data scientists who create them. A well-designed ModelOps platform includes the continuously updated model inventory that captures all the necessary docu- mentation and metadata for every model, including any changes and approvals. MLCs capture all KPIs and codify policies into repeatable processes. Automating MLCs enables continuous test- ing and monitoring, making it easy to flag and remediate issues and ensure that approvals are completed quickly. With all the information concerning each model captured in a common plat- form, generating reports to comply with audits also becomes far easier. Visualizing the Results A key objective for an enterprise ModelOps capability is to visu- alize the status of all models in production, regardless of where they were created or acquired, and independent of where they execute. You can accomplish this objective in several ways: » With appropriate interfaces and
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