Policy Register

Automated decision-making procedure

Which decisions are made or assisted by a system, how a person can be involved, what the data subject is told, and how a decision is contested.

How the register reads it

Also calledprofiling procedure, human oversight procedure
FamilyAI and automated decisions
Document typeProcedure. The regimes ask for the content, not the label; a line pasted as a standard, procedure, plan or schedule is placed here with the label noted.
Folds intoThe regimes accept it folded into the ai use policy (acceptable ai use); when neither is listed, the gap is counted once, under the parent.
Expected ownerThe AI governance lead (CTO, CDO or head of data science).
Review cadenceAnnual (the register's default: the clauses say planned intervals and on significant change, and do not fix a period).
On the gap list whenGDPR is ticked and no line resolves to it or to its parent (ISO 27701, ISO 42001 require it too, inside a parent document, so they do not list it separately).
TemplateNo template yet. The clauses below say what the document is expected to contain.

Which standards require it, and what each expects it to contain

3 requiring clauses, 3 regimes

Shown on a register for the regimes you tick; with none ticked, ISO 27001 is applied. Requirement text drawn from a human-verified compliance corpus under licence: the corpus statement of each clause, not the instrument verbatim.

ISO/IEC 27701:2025

ISO 27701 A.1.3.11 Automated decision making

The organization must identify and address the obligations, including legal obligations, that it owes to individuals arising from decisions it makes about them based solely on automated processing of their personal data, taking account of jurisdictions that impose specific obligations where such decisions significantly affect the individual, such as notifying that automated decision making exists, allowing objection to it, or providing human intervention, and of jurisdictions where some processing may not be fully automated at all.

Evidence an auditor accepts: Inventory of decisions made solely by automated processing, with their effect on individuals assessed; obligations register per jurisdiction for those decisions; notification content disclosing the existence and logic of automated decision making
Common gap: Automated decisions unrecognised as such because a person nominally approves an output they never question, which is not meaningful human involvement
Source: ISO/IEC 27701:2025

ISO/IEC 42001:2023

ISO 42001 A.9.4 Intended use of the AI system

The organization shall ensure that the AI system is used according to the intended uses of the AI system and its accompanying documentation.

Evidence an auditor accepts: Intended use statements; use case approval records; monitoring of use
Common gap: Is off-label use detected and addressed?
Source: ISO/IEC 42001:2023

GDPR (Regulation (EU) 2016/679)

GDPR Art. 22 Automated individual decision-making, including profiling

Do not subject a data subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision is necessary for entering into or performing a contract between the data subject and the controller, is authorised by Union or Member State law that lays down suitable safeguards, or is based on the data subject's explicit consent. Where the contract or explicit consent route is used, implement suitable measures to safeguard the data subject's rights, freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express a point of view and to contest the decision. Such decisions must not be based on special categories of personal data unless explicit consent or substantial public interest applies and suitable safeguards are in place.

Evidence an auditor accepts: An inventory of automated decisions with the assessment of whether each produces legal or similarly significant effects; the exception relied on for each in scope decision, and for contract based ones the necessity reasoning rather than a convenience argument; the human intervention process, showing the reviewer has the authority and the information to change the outcome
Common gap: A rubber stamp reviewer treated as human involvement, which leaves the decision solely automated in substance
Source: GDPR (Regulation (EU) 2016/679)

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