# Underrepresentation, Label Bias, and Proxies: Towards Data Bias Profiles for the EU AI Act and Beyond

arXiv: https://arxiv.org/abs/2507.08866 · HTML: https://mlsanity.com/paper/2507.08866/

## Key facts

- Cited by 2 papers in the map (data through 14 Oct 2026).
- Builds on 40 of its 77 references that are in the map.
- First posted on arXiv 9 Jul 2025.

## Builds on (most cited first, 30 of 40)

- [Equality of Opportunity in Supervised Learning](https://mlsanity.com/paper/1610.02413/) (2016)
- [A Survey on Bias and Fairness in Machine Learning](https://mlsanity.com/paper/1908.09635/) (2019)
- [Datasheets for Datasets](https://mlsanity.com/paper/1803.09010/) (2018)
- [ChestX-ray8: Hospital-scale Chest X-ray Database and Benchmarks on Weakly-Supervised Classification and Localization of Common Thorax Diseases](https://mlsanity.com/paper/1705.02315/) (2017)
- [Certifying and removing disparate impact](https://mlsanity.com/paper/1412.3756/) (2014)
- [Retiring Adult: New Datasets for Fair Machine Learning](https://mlsanity.com/paper/2108.04884/) (2021)
- [Learning Adversarially Fair and Transferable Representations](https://mlsanity.com/paper/1802.06309/) (2018)
- [Measurement and Fairness](https://mlsanity.com/paper/1912.05511/) (2019)
- [Empirical Risk Minimization under Fairness Constraints](https://mlsanity.com/paper/1802.08626/) (2018)
- [A Framework for Understanding Sources of Harm throughout the Machine Learning Life Cycle](https://mlsanity.com/paper/1901.10002/) (2019)
- [Censoring Representations with an Adversary](https://mlsanity.com/paper/1511.05897/) (2015)
- [Evaluating Deep Neural Networks Trained on Clinical Images in Dermatology with the Fitzpatrick 17k Dataset](https://mlsanity.com/paper/2104.09957/) (2021)
- [Data Cards: Purposeful and Transparent Dataset Documentation for Responsible AI](https://mlsanity.com/paper/2204.01075/) (2022)
- [No Classification without Representation: Assessing Geodiversity Issues in Open Data Sets for the Developing World](https://mlsanity.com/paper/1711.08536/) (2017)
- [CheXclusion: Fairness gaps in deep chest X-ray classifiers](https://mlsanity.com/paper/2003.00827/) (2020)
- [Bias Mitigation for Machine Learning Classifiers: A Comprehensive Survey](https://mlsanity.com/paper/2207.07068/) (2022)
- [Fairness in Deep Learning: A Computational Perspective](https://mlsanity.com/paper/1908.08843/) (2019)
- [Learning Certified Individually Fair Representations](https://mlsanity.com/paper/2002.10312/) (2020)
- [Fair Classification with Group-Dependent Label Noise](https://mlsanity.com/paper/2011.00379/) (2020)
- [On Formalizing Fairness in Prediction with Machine Learning](https://mlsanity.com/paper/1710.03184/) (2017)
- [It's COMPASlicated: The Messy Relationship between RAI Datasets and Algorithmic Fairness Benchmarks](https://mlsanity.com/paper/2106.05498/) (2021)
- [Algorithmic Fairness Datasets: the Story so Far](https://mlsanity.com/paper/2202.01711/) (2022)
- [The Fairness of Risk Scores Beyond Classification: Bipartite Ranking and the xAUC Metric](https://mlsanity.com/paper/1902.05826/) (2019)
- [Fair Normalizing Flows](https://mlsanity.com/paper/2106.05937/) (2021)
- [Arbitrariness and Social Prediction: The Confounding Role of Variance in Fair Classification](https://mlsanity.com/paper/2301.11562/) (2023)
- [Identifying and Improving Disability Bias in GPT-Based Resume Screening](https://mlsanity.com/paper/2402.01732/) (2024)
- [Long-Term Fairness with Unknown Dynamics](https://mlsanity.com/paper/2304.09362/) (2023)
- [Ground(less) Truth: A Causal Framework for Proxy Labels in Human-Algorithm Decision-Making](https://mlsanity.com/paper/2302.06503/) (2023)
- [Unprocessing Seven Years of Algorithmic Fairness](https://mlsanity.com/paper/2306.07261/) (2023)
- [Metrics for Dataset Demographic Bias: A Case Study on Facial Expression Recognition](https://mlsanity.com/paper/2303.15889/) (2023)

## Built on by (most cited first, 2 of 2)

- [Textual Data Bias Detection and Mitigation -- An Extensible Pipeline with Experimental Evaluation](https://mlsanity.com/paper/2512.10734/) (2025)
- [No evaluation without fair representation : Impact of label and selection bias on the evaluation, performance and mitigation of classification models](https://mlsanity.com/paper/2603.09662/) (2026)

## Abstract (arXiv)

Undesirable biases encoded in the data are key drivers of algorithmic discrimination. Their importance is widely recognized in the algorithmic fairness literature, as well as legislation and standards on anti-discrimination in AI. Despite this recognition, data biases remain understudied, hindering the development of computational best practices for their detection and mitigation. In this work, we present three common data biases and study their individual and joint effect on algorithmic discrimination across a variety of datasets, models, and fairness measures. We find that underrepresentation of vulnerable populations in training sets is less conducive to discrimination than conventionally affirmed, while combinations of proxies and label bias can be far more critical. Consequently, we develop dedicated mechanisms to detect specific types of bias, and combine them into a preliminary construct we refer to as the Data Bias Profile (DBP). This initial formulation serves as a proof of concept for how different bias signals can be systematically documented. Through a case study with popular fairness datasets, we demonstrate the effectiveness of the DBP in predicting the risk of discriminatory outcomes and the utility of fairness-enhancing interventions. Overall, this article bridges algorithmic fairness research and anti-discrimination policy through a data-centric lens.
