Agency predictive model documentation (Texas Department of Insurance)

Todd Feathers filed this request with the Texas Department of Insurance of Texas.
Tracking #

R013687-102621

Multi Request Agency predictive model documentation
Status
Rejected

Communications

From: Todd Feathers

To Whom It May Concern:

Pursuant to the Texas Public Information Act, I hereby request the following records:

1) Executive summaries, algorithmic impact reports, predictive model reports, and/or model validation studies dating from Jan. 1, 2017 until the present for all predictive analytics tools and automated decision systems (ADS) used by the agency. This includes predictive models and ADSs built in-house as well as those built by vendors for the agency or those used by agency employees through third-party software.

2) All contracts and statements of work regarding the purchase and/or creation of tools identified in response to part one of this request.

2) A data dictionary/library for each predictive model and ADS identified in response to part one of this request. Please note: Data dictionaries list the names of data fields (i.e. column headers in a spreadsheet), they do not contain the actual data analyzed by models.

If you have any questions regarding this request, please don't hesitate to contact me for further clarification.

I ask that all fees be waived as I am a journalist and intend to use the requested records to publish articles in the public interest. In the event you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of each employee involved and an explanation justifying the employee hours required to fulfill the request.

Should you choose to reject this request or redact portions of responsive documents, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portions from public review.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Todd Feathers

From:

Dear Todd Feathers: We got your open records request on 10/26/2021 12:15:30 AM.
Visit My Request Center and enter reference number R013687-102621 to:

* Check the status of your request.
* Send us a message about your request. See the estimated cost for the records you requested. It takes about five days from the date you submitted your request to see the estimate. We can complete many requests for free. But if you're getting paper copies, or if we have a lot of documents to review, there might be a cost. If the cost is more than $40, we’ll send you an estimate for your approval before sending the records to you. If it’s less than $40, we won’t send an estimate, and you’ll get a bill after we send the records. Reference number: R013687-102621 Date of your request: 10/26/2021 12:15:30 AM Information you requested: To Whom It May Concern:

Pursuant to the Texas Public Information Act, I hereby request the following records:

1) Executive summaries, algorithmic impact reports, predictive model reports, and/or model validation studies dating from Jan. 1, 2017 until the present for all predictive analytics tools and automated decision systems (ADS) used by the agency. This includes predictive models and ADSs built in-house as well as those built by vendors for the agency or those used by agency employees through third-party software.

2) All contracts and statements of work regarding the purchase and/or creation of tools identified in response to part one of this request.

2) A data dictionary/library for each predictive model and ADS identified in response to part one of this request. Please note: Data dictionaries list the names of data fields (i.e. column headers in a spreadsheet), they do not contain the actual data analyzed by models.

If you have any questions regarding this request, please don't hesitate to contact me for further clarification.

I ask that all fees be waived as I am a journalist and intend to use the requested records to publish articles in the public interest. In the event you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of each employee involved and an explanation justifying the employee hours required to fulfill the request.

Should you choose to reject this request or redact portions of responsive documents, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portions from public review.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Todd Feathers

Upload documents directly: https://www.muckrock.com/ Questions?
Please call our Open Records Office at 512-676-6551.
Stay Connected with the Texas Department of Insurance: (https://u8387778.ct.sendgrid.net/ls/click?upn=bQH7YI59fmjg-2BFK-2B4CL7ZJ0gFfkWmRMPgrfE-2FjLVroOjTpdoGkI3bpesDr-2BfLqb9pBOH_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcWX3-2FmxqVfhMILamJQngJJIefSatSuLMK2idcIYN6d-2BPy7dchnYG7LtnMmDFAQuEAkutLdvfma-2Bh-2FG0wlivPzeGtOosvR2FRJJqMy9HAdPIX3QQQdygBSCSLcXZrjYNJUrxIeP5YKFfpbxBknP1Gmnz) Twitter | (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1Hfb0BSJJ3TfgS41x8aBPJtb69UkbuUdzObaYkE5Gese44_nU_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcVUsIFHOBKIfubxJ7mfA7tXGTTbucUvLpdpgHLIygpTaCpPmOS-2FLn5gRqVQFLv3uz8fcWIOfbeTpoiA94SBNIW7GFjUHyqi96B6LCDTXo6fsJ-2FBcwR-2B7ehYMm2QEPbDlzyKSjoSN3gKZATLOmMarNP4) Facebook | (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1HT507z6YEhWiWExxI5F-2FLbNf-2FcpX0urbbxwPf7Mjc3VTGHrTXfsWMRZGloMcOVLPKg-3D-3D9117_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcX1Gl2QQpZNLgxh7xGm62iUq3oYI-2BsgfE0EQdCTOivjQbAc7b0Ejyo0-2Bk4ZAa53iXPnLQfHpIF1mmeMJxwaAWfb88x4Y4Gc7x4lUBtDHiHaB1Cf8HyiyQS0qqhEqGOoQgksCi-2FzfbwM5JyQ9Da8AgdQ) LinkedIn | (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1HeVpgn3GUUoA3Q8VYNoAfzI2nRF38YGMY8eIu4kgMqpqeWcLprYK6kV3e0gJLv43YZE5Vel2Q-2BXBODZH1-2BuR-2B9c-3DGTY9_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcU9jKOa5qrtKiKuAWqeTZv6IIwb2oBnC-2F9hDL6yVh9TwhPKcXJyADcQSA9b6N0tn5LEz-2Fs-2BM87Cvy126UwVvOSERI0z2t4Bv735gcac2uhVJ6vCq8sA81XZdCpHbvtx3pj3NC3ynTrGd9MICHD4YCAJ) YouTube | (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1Hdaz7MGK4ooYKWKNfInSTLtpL0uzS8CQUR-2F9t6cnb22g4-2BLi57V0EG-2FqJcCiHtszTvwc53g-2BUkG8KV-2BYhncTIPI-3DSa1k_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcWfjOv0Ccgb6RnR-2B-2BgMNz1E7Mri-2BfrtvuY7Adh3uencN4ZuJyPrIjtH7ytCjiwmKpDPeqfvAnTa9oVB9NmMnRU6u5mb6g19aGg8wIgNFsuJSJSWFZuuTSEYNI9ur66Qm50OUIJfyz1aZ-2BZXpJ0MGq0J) Subscribe (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1HZ54JlEuA8kMi-2FtD88s-2BmJF466WdvcuCMD3k6cN-2FemjcjrCzM-2B-2Fy9nuMi7xzyy4NzDCKXKDh0kXqxOMSkVY5TAk-3DRNv3_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18BO6bexl5jXMbWFZkmbA6Mt5x6AkeUK8sHANlAI76O0eSP-2BObLA2Lwq6FkX-2BP1kOYVveP43x3rTgwiC8r9bWIoCujXEdd6-2B4ZUPtfo9MhmdBz-2FzLqsdcTWZ965olQVzK-2FsV8-2FPmRtkk5sq3pu2CcJcWCotdcxkh5LrM0i8jNY4-2F6o5-2Byf0LOxSH-2BUZXa9oCtEod8lNqMskbh5f9CAQxNEHf9-2BtdWP8FIz-2Btv8o-2B75BIRYvztyCCsgi0Gd8F3pwnHtdAVhi9a8q65VJ-2BzZPKmHRIR-2Fp63UMM4B8ZZrJoz13mY)

From: Texas Department of Insurance

Hello Mr. Feathers,

We need a clarification about your open records request, (R013687) in order to continue. Can you please define "predictive analytics tools" and "automated decision systems." If you could provide more context, or examples of what you're looking for, it may help us identify if we have anything responsive.

We'll need this clarification in writing in order to proceed, but you can just respond to this email.

If we don't hear back within 61 days we'll consider the request withdrawn.

Ben Gonzalez
Media Relations
512-676-6595
Stay connected with the Texas Department of Insurance<http://www.tdi.texas.gov/>:
Twitter<https://twitter.com/texastdi> | Facebook<https://www.facebook.com/TexasDepartmentofInsurance/> | LinkedIn<https://www.linkedin.com/company/texas-department-of-insurance> | YouTube<https://www.youtube.com/channel/UC0ROJMNKu2zHd6D0Mi2Gjtw> | Subscribe<https://public.govdelivery.com/accounts/TXINSUR/subscriber/new>

[cid:image003.jpg@01D7CFE1.46F854F0]

From: Todd Feathers

Hello Ben,

Thanks very much for your help with this. I know the request is a bit broad, so I appreciate you asking for clarification. I'm researching the different way government agencies uses these tools, so I wanted to cast a wide net.

These are just a few hypothetical examples, but within the field of insurance, predictive analytics or ADS systems might be used to detect fraud, suggest rates based on the likelihood that an adverse event (a wildfire, say) will affect a particular policy holder, or generally predict the risk that any particular event will happen.

Hope that helps, and please don't hesitate to reach out if you have any more questions.

I'm also happy to limit my request to the timeframe Jan. 1, 2018 to the present in order to facilitate the search.

Todd

From: Texas Department of Insurance

Hello Todd,

We are unable to identify any systems at the agency that match your description. None of our electronic systems are used to make predictions or decisions.

The one AI type system that we use is a text scanning tool (Mozart for Regulators) that allows us to quickly identify novel language in filings. That simply identifies sections for our human staff to focus on, in order to consider changes to past versions of similar filings. It is never used for decision making.

You can read more about that system on our website here: TDI applies advanced technology to policy reviews<https://www.tdi.texas.gov/news/2020/tdi08032020.html>.

If you would like more information about TDI's use of Mozart for regulators, please respond to this email to clarify your request again with the details you're interested in. If you have no further clarifications on this request, we'll consider it closed and withdrawn after 61 days.

Best,

Ben Gonzalez
Media Relations
512-676-6595
Stay connected with the Texas Department of Insurance<http://www.tdi.texas.gov/>:
Twitter<https://twitter.com/texastdi> | Facebook<https://www.facebook.com/TexasDepartmentofInsurance/> | LinkedIn<https://www.linkedin.com/company/texas-department-of-insurance> | YouTube<https://www.youtube.com/channel/UC0ROJMNKu2zHd6D0Mi2Gjtw> | Subscribe<https://public.govdelivery.com/accounts/TXINSUR/subscriber/new>

[cid:image001.jpg@01D7DAD3.73F9BBE0]

CONFIDENTIALITY NOTICE: The information transmitted in this email is confidential and/or privileged as an attorney-client communication or attorney work product and is intended only for the person or entity to which it is addressed. If you are not an intended recipient, you are hereby notified that any review, use, or copying of this email and/or its attachments (if any) is prohibited. Please immediately notify the sender and delete without reading it.

From:

Dear Todd Feathers,
In regards to the Open Records Request received on 10/26/2021 requesting records, the records have been in "Requested Clarification" status for 61 days. The Texas Department of Insurance considers this request closed. If you would still like the records, please submit another Open Records Request. Thank you for using the TDI Open Records.
Request Details:
Reference # R013687-102621
Description of Records Requested: To Whom It May Concern:

Pursuant to the Texas Public Information Act, I hereby request the following records:

1) Executive summaries, algorithmic impact reports, predictive model reports, and/or model validation studies dating from Jan. 1, 2017 until the present for all predictive analytics tools and automated decision systems (ADS) used by the agency. This includes predictive models and ADSs built in-house as well as those built by vendors for the agency or those used by agency employees through third-party software.

2) All contracts and statements of work regarding the purchase and/or creation of tools identified in response to part one of this request.

2) A data dictionary/library for each predictive model and ADS identified in response to part one of this request. Please note: Data dictionaries list the names of data fields (i.e. column headers in a spreadsheet), they do not contain the actual data analyzed by models.

If you have any questions regarding this request, please do
To view the full details of this request please log into the TDI Open Records. (https://u8387778.ct.sendgrid.net/ls/click?upn=6HtRfOYLt5fXvpttM-2FU1Hd3xR95m4mrvm6qbDFQ6T21AJ9-2BYx5BWPgpzgq3iWEWacxAWDE6-2Bk2A4g1X44i-2FYd6vXjOqkb57myNsMam6MDY8-3DGGWY_VBiIIav5Jw2tTN90FxmFIScuK4AHU775pjkSHfOVUv0LWxKLtuWzDz8BohL2xIz6-2BEdhHTrEzs-2BhF-2B87amH18OUloYNWRg2UOK0qF7rivg8s2yG8gwaTAeEj2AG5yyzhuvot-2FTs83Hve-2FSxZunuOEwPybWmz-2BsdSG2hvMGIuOKi1dJw2BV2XRfjBrjapmNZB9iPMgRHqV-2BEmp9HA1XZwwZDidc66gelj4X07fymWb8aaW5fhaLn7f9y5bjLO6zZW4L3LUXvV6uzVxRItUHjBPBWTWADkw5mIKQ0sSQSrFiMqQ3GnblzMd2FDw6gVJ4EI6gL7YMaampb3v0m2UGtVHU9NkXFS5lar0svvIPlfdpI4Yjmuiefut3Rj169SjIQP) This is an auto-generated email from an unmonitored email account. Please DO NOT REPLY

Files

pages

Close