Auditing a Dutch Public Sector Risk Profiling Algorithm Using an Unsupervised Bias Detection Tool

Algorithms are increasingly used to automate or aid human decisions, yet recent research shows that these algorithms may exhibit bias across legally protected demographic groups. However, data on these groups may be unavailable to organizations or external auditors due to privacy legislation. This paper studies bias detection using an unsupervised clustering tool when data on demographic groups are unavailable. We collaborate with the Dutch Executive Agency for Education to audit an algorithm that was used to assign risk scores to college students at the national level in the Netherlands between 2012-2023. Our audit covers more than 250,000 students from the whole country. The unsupervised clustering tool highlights known disparities between students with a non-European migration background and Dutch origin. Our contributions are three-fold: (1) we assess bias in a real-world, large-scale and high-stakes decision-making process by a governmental organization; (2) we use simulation studies to highlight potential pitfalls of using the unsupervised clustering tool to detect true bias when demographic group data are unavailable and provide recommendations for valid inferences; (3) we provide the unsupervised clustering tool in an open-source library. Our work serves as a starting point for a deliberative assessment by human experts to evaluate potential discrimination in algorithmic-supported decision-making processes.