Question 22
Domain 2: Privacy Risk ManagementA hiring model gives lower scores to applicants from certain ZIP codes. The feature is not explicitly prohibited in every market. What is the best advice from the privacy technologist?
Correct answer: C
Explanation
A ZIP code can function as a proxy for protected traits like race or income, so the model should be tested for disparate impact even if the feature is not “explicitly prohibited in every market.” If it does, the safer advice is to “assess whether the feature acts as a proxy for protected characteristics and redesign if it does.”
Why each option is right or wrong
A. Keep the feature if it improves prediction accuracy.
B. Treat the ZIP code as potentially sensitive only after a complaint is filed.
C. Assess whether the feature acts as a proxy for protected characteristics and redesign if it does.
Under anti-discrimination rules, a facially neutral input can still create unlawful disparate impact if it serves as a proxy for a protected trait; the relevant analysis is not whether ZIP code is expressly banned everywhere, but whether its use produces disparate treatment or disparate impact on a protected class. In employment settings, that means testing the feature for correlation with race, national origin, or other protected characteristics and, if the proxy effect is present, removing or redesigning the feature rather than relying on jurisdiction-by-jurisdiction permissibility.
D. Move the decision to a vendor so the employer no longer owns the risk.