“…In particular, individual transparency rights largely occur after the fact of algorithmic development, when it is far more difficult (if not impossible) to impose accountability or corrections on a system. 152 By contrast, the GDPR's systemic accountability measures are envisioned as ongoing and continuous, 153 and should be implemented early on in an algorithm's development. This creates, in theory at least, internal, expert/third-party, and regulatory oversight over the development of an algorithm from its inception, better serving the instrumental purposes of correcting error, inaccuracy, and bias in a changing system, over time.…”