Deep synthesis
Do deep synthesis algorithms have to be assessed? How long are logs kept?
Basis: Provisions on the Administration of Deep Synthesis of Internet Information Services (互联网信息服务深度合成管理规定)
Conclusion: Yes. Providers and technical supporters shall periodically review, assess and verify the mechanism of generative and synthesized algorithms. Anyone offering tools to edit biometric information such as faces and voices, or tools involving special objects and scenes that are not biometric, shall carry out a security assessment in accordance with law, either themselves or through a professional institution. They must also review both input data and synthesized results, build a feature library for identifying illegal and harmful information, and record and retain network logs.
What you may need to do
- Turn review of the algorithm mechanism into a recurring action and keep the records
- Run security assessments for tools involving faces, voices or special scenes
- Review input and output in both directions, with clear entry criteria for the feature library
- Set up a log retention policy so records can be traced and retrieved
Provisions relied on
Provisions on the Administration of Deep Synthesis of Internet Information Services (互联网信息服务深度合成管理规定) Article 15
Deep synthesis service providers and technical supporters shall strengthen technical management, and periodically review, assess and verify the mechanism of generative and synthesized algorithms.
Provisions on the Administration of Deep Synthesis of Internet Information Services Article 10
A deep synthesis service provider shall establish and improve a feature library for identifying illegal and harmful information, improve the entry criteria, rules and procedures, and record and retain the relevant network logs.
Provisions on the Administration of Deep Synthesis of Internet Information Services Article 16
For information content generated or edited using its service, a deep synthesis service provider shall take technical measures to add a label that does not affect users’ use of the service, and shall preserve log information in accordance with laws, administrative regulations and relevant state provisions.
One-line conclusion
Technical management is not a one-off action: the algorithm mechanism must be periodically reviewed, assessed and verified; tools involving biometric information such as faces and voices, or special objects and scenes bearing on national security and national image, must go through a security assessment; on the content side both input data and synthesized results must be reviewed, with a feature library for identifying illegal and harmful information; and both network logs and labeling-related logs must be recorded and retained so they can be traced.
Basis
Article 15: “Deep synthesis service providers and technical supporters shall strengthen technical management, and periodically review, assess and verify the mechanism of generative and synthesized algorithms.” It also requires a security assessment for two kinds of tools: “(1) those that generate or edit biometric information such as faces and voices; (2) those that generate or edit non-biometric information such as special objects and scenes that may involve national security, national image, national interests and public interests.”
Article 10: “A deep synthesis service provider shall strengthen the management of deep synthesis content, and review the input data and synthesized results of deep synthesis service users by technical or manual means. A deep synthesis service provider shall establish and improve a feature library for identifying illegal and harmful information, improve the entry criteria, rules and procedures, and record and retain the relevant network logs.”
Article 16 adds the log requirement: take technical measures to add a label that does not affect users’ use, “and preserve log information in accordance with laws, administrative regulations and relevant state provisions.”
What you need to do
- Make review of the algorithm mechanism a recurring task, and keep the process records and conclusions of each review, assessment and verification.
- Check whether you are one of the two tool types that must undergo a security assessment: editing of biometric information such as faces and voices, and generating or editing special objects and scenes that may affect national security, national image, national interests and public interests. If you are, assess it yourself or through a professional institution, and archive the materials.
- Review content in both directions: input prompts and source material must be reviewed, and so must synthesized results. Technical and manual means can be combined.
- The feature library needs entry criteria, rules and procedures, with records of updates, instead of relying on a model bought once.
- Build log retention into the technical design: retention scope, storage location, access permissions and retrieval procedure, each with a named owner.
Common pitfalls
- Reviewing only output and not input, so nothing stops a prompt carrying prohibited intent.
- Running the security assessment once and archiving it, with no re-check after the model iterates or new templates ship.
- Keeping logs in the business database where they are auto-purged or rolled over, so they cannot be produced when needed.
- Inventing a retention period because the Provisions do not state a number of days, and writing it into external documents. The number of days should follow the applicable laws, administrative regulations and relevant state provisions.
- Reading “periodically” as “before launch”, and never re-checking afterwards.
Frequently asked follow-ups
Q: How long do logs have to be kept? A: These Provisions require “recording and retaining the relevant network logs” and “preserving log information in accordance with laws, administrative regulations and relevant state provisions”, without specifying a number of days. The number of days follows the applicable laws, regulations and relevant state provisions, and the local cyberspace administration office sets the operative reading.
Q: If an external institution does the security assessment, does the provider still bear responsibility? A: Article 15 allows a security assessment to be carried out “either by itself or through a professional institution”, but the duty holder remains the deep synthesis service provider and technical supporter, and the assessment conclusions and remediation actions still have to be accounted for internally.
Frequently asked follow-ups
- What if a small team cannot run a security assessment?
- It can commission a professional institution, or set up a traceable assessment process internally as required by Article 15; what matters is that the object, method, conclusion and remediation records are all complete.
- Is the feature library mandatory?
- Article 10 explicitly requires building and improving a feature library for identifying illegal and harmful information, with entry criteria, rules and procedures — a legal duty, not an option.