Accountability Capture: How Record-Keeping to Support AI Transparency and Accountability (Re)shapes Algorithmic Oversight

Abstract: Accountability regimes typically encourage record-keeping to enable the transparency that supports oversight, investigation, contestation, and redress. However, implementing such record-keeping can introduce considerations, risks, and consequences, which so far remain under-explored. This paper examines how record-keeping practices bring algorithmic systems within accountability regimes, providing a basis to observe and understand their effects. For this, we introduce, describe, and elaborate 'accountability capture' -- the re-configuration of socio-technical processes and the associated downstream effects relating to record-keeping for algorithmic accountability. Surveying 100 practitioners, we evidence and characterise record-keeping issues in practice, identifying their alignment with accountability capture. We further document widespread record-keeping practices, tensions between internal and external accountability requirements, and evidence of employee resistance to practices imposed through accountability capture. We discuss these and other effects for surveillance, privacy, and data protection, highlighting considerations for algorithmic accountability communities. In all, we show that implementing record-keeping to support transparency in algorithmic accountability regimes can itself bring wider implications -- an issue requiring greater attention from practitioners, researchers, and policymakers alike.