Empirical Privacy Variance

We propose the notion of empirical privacy variance and study it in the context of differentially private fine-tuning of language models. Specifically, we show that models calibrated to the same (ε, δ)-DP guarantee using DP-SGD with different hyperparameter configurations can exhibit significant variations in empirical privacy, which we quantify through the lens of memorization. We investigate the generality of this phenomenon across multiple dimensions and discuss why it is surprising and relevant. Through regression analysis, we examine how individual and composite hyperparameters influence empirical privacy. The results reveal a no-free-lunch trade-off: existing practices of hyperparameter tuning in DP-SGD, which focus on optimizing utility under a fixed privacy budget, often come at the expense of empirical privacy. To address this, we propose refined heuristics for hyperparameter selection that explicitly account for empirical privacy, showing that they are both precise and practically useful. Finally, we take preliminary steps to understand empirical privacy variance. We propose two hypotheses, identify limitations in existing techniques like privacy auditing, and outline open questions for future research.