Summary
This paper proposes a new method for auditing DP-SGD in a black-box setting, where the auditor can only see the final parameters of the model (rather than intermediate steps). The main idea is to select worst-case initial model parameters; this seems to give a substantial advantage to the black-box analysis.
Strengths
The idea of selecting worst-case initial parameters for auditing is clever. Empirically, the proposed method strongly outperforms the chosen baseline.
This work shows that a (partially) black-box adversary isn't much weaker than a white-box one; this demonstrates that DP analyses (which assume the latter) may not be underestimating privacy too much.
The paper is well-presented.
Weaknesses
# Motivations
I think the authors should refine their motivations. They use two: 1) their method is good for detecting bugs, and 2) it provides insights into DP-SGD analyses.
1. Bugs.
The ultimate purpose of _black-box_ auditing is unclear. There's two sides to this discussion. On the one hand, if our goal is to audit a DP-SGD implementation, surely we should be making all the worst-case assumptions (i.e., give as much advantage to the auditor as possible) to look for bugs. On the other hand, if our goal is to evaluate real-world attacks against DP-SGD, then it does make sense to consider a black-box assumption. The assumptions this paper makes are a bit of an hybrid: it assumes black-box for auditing, yet the adversary is allowed to specify the initial model parameters. The only semi-practical scenario I can think of is an attacker who creates a model (for subsequent fine-tuning to be carried out by the victim) and wants to augment the leakage in the fine-tuned version of the model. Aside from this scenario, I would recommend leaving out from this paper any motivation arguing that this work is more practical than other auditing methods for finding "bugs"; please refer to "Questions" for a concrete example.
2. New insights.
The authors do provide one very convincing motivation: a big question is whether DP analyses of DP-SGD could be improved if they considered it as a black-box algorithm; currently, they all assume knowledge of intermediate gradients. This work offers some hope: from the analysis, it seems that the difference between black-box and the theoretically estimated "epsilon" may be closer than expected. If I may, I would strongly recommend the authors to center their motivations on this aspect.
# Comparison
I could not find a real comparison to previous auditing methods. Only two numbers appear (within the Datasets paragraph), reporting the performance of previous works; were these computed under the same experimental setting (and code base)? Ideally, they should be replicated under identical conditions to yours.
Secondly, it'd be very interesting to see what similar white-box methods achieve, in comparison. How tight are they, on those datasets/models?
Questions
- "Although techniques to tightly audit DP-SGD exist in literature [26, 27], they do so only in active white-box threat models, where the adversary can observe and insert arbitrary gradients into the intermediate DP-SGD steps. However, real-world adversaries cannot always access the model’s inner parameters, let alone insert arbitrary gradients."
As argued above, I don't think this is a valid premise. There's nothing in auditing that requires modelling a real-world adversary. Further, the assumptions that you make (e.g., worst-case initial parameters) do not correspond to a real-world adversary. I think the implications of what you claim here are incorrect, and I don't think it should be part of your motivations.
- Threat model. It does look weird to see a threat model section in an auditing paper, and I would humbly recommend removing it: DP doesn't specify any particular threat model, and auditing is just about ensuring how tightly the definition is being matched empirically. If you do want to keep this section, please note that it's missing the assumption that the auditor (adversary?) can specify the initial model parameters; also, I was unclear as to what the following meant in this context: "assume that the adversary can choose a worst-case target sample as is standard for auditing DP mechanisms".
- "we set B=N".
Can you please clarify whether this is a constraint of your method, and if so what are the potential limitations?
- Sentence "When auditing a DP mechanism [...]". Please define the symbol $R$. (It's clear what it is, but it's undefined.)
- "Crafting worst-case initial parameters". This should be one of the main contributions, but unfortunately the paragraph doesn't provide much information on how exactly these parameters are created. Can you please provide more information in the text (and in rebuttal)?
- Could you please double check: did your cluster only have 1 CPU core?
- Typo "is is".
Limitations
These were adequately addressed.