Apply safeguards to solely automated decisions with significant effects
Download: JSON · MarkdownUnder ICO AI guidance, UK GDPR Article 22 as amended by the Data (Use and Access) Act 2025
What this label means
- Verified
- — a named reviewer opened the official source and confirmed the record; the date and the reviewer are shown.
- Pending review
- — linked to the official source and in the queue for a reviewer to confirm.
- Source-linked
- — linked to the official source, not yet confirmed by a reviewer.
On this page 9 sections
In brief
Apply safeguards to solely automated decisions with significant effects is a legal requirement under the ICO AI guidance in the United Kingdom (UK GDPR Article 22 as amended by the Data (Use and Access) Act 2025). The record carries 1 evidence example and mappings to 1 framework.
- Instrument
- ICO AI guidance
- Jurisdiction
- United Kingdom
- Nature
- Legal requirement
- Source reference
- UK GDPR Article 22 as amended by the Data (Use and Access) Act 2025
- Who it binds
- Deployer / user organisation, Public authority / government body
- Evidence examples
- 1
- Framework mappings
- NIST AI Risk Management Framework 1.0
- Controls that meet it
- 3
- Official source
- Open official text
- Verification
- Source-linked
What does it require?
Individuals have rights in relation to solely automated decisions that produce legal or similarly significant effects, including being told about the decision, obtaining human intervention, and contesting it. The Data (Use and Access) Act 2025 amended these rules; the reviewer must confirm the current wording.
Practical action
Map every significant automated decision, add a human-review route and a notice to affected people.
Who does it apply to?
Any controller making solely automated decisions with legal or similarly significant effects.
Which controls meet this duty?
Satisfies: the control, operated properly, does the work the duty asks for. Supports: it contributes but the duty needs more. Each control page lists every other duty it serves, so work done once can be counted once.
-
satisfiesProcessCustomer operations lead · once per ai systemDecision explanation, human review and appeal route
Serves 12 recorded duties · evidence: Adverse-decision explanation template, AI decision challenge and human review procedure, Challenge and reversal log
Notice, human intervention and contest route for significant automated decisions.
-
supportsProcessAI system owner · once per ai systemHuman oversight design and override procedure
Serves 12 recorded duties · evidence: Human oversight and override procedure, Human-involvement design rationale, Overseer training completion
Meaningful human intervention design.
-
supportsProcessProduct owner · at launch and on material changeAI interaction and use disclosure notices
Serves 18 recorded duties · evidence: AI interaction or use notice, Notice catalogue, Notice wording approval
Telling people a solely automated decision was made.
Templates that cover this duty
Generated from the records. Free · no account · links emailed to your work address. This duty is cited in each file with its source reference and a link back here.
- Human Oversight Procedure
Procedure · DOCX and XLSX · v5
- AI Agent Registry and Permission Matrix
Register · XLSX and DOCX · v6
- NIST AI RMF ↔ EU AI Act ↔ ISO/IEC 42001 Crosswalk
Crosswalk · XLSX · v3
- AI Audit Evidence Tracker
Register · XLSX · v1
What evidence would a reviewer expect?
| Evidence | Type | Notes |
|---|---|---|
| Automated decision register and review procedure | register |
Framework mappings
Original editorial crosswalks. They cite clause numbers only and reproduce no standard text; confidence reflects how direct the mapping is.
See every United Kingdom duty mapped this way →
| Framework | Reference | Note | Confidence |
|---|---|---|---|
| NIST AI RMF 1.0 | GOVERN 5.x, MANAGE 4.x | Recourse mechanisms. | medium |
Frequently asked questions
Is this a legal requirement?
Yes. It is a legal requirement under ICO AI guidance (UK GDPR Article 22 as amended by the Data (Use and Access) Act 2025).
Who must comply with this obligation?
Any controller making solely automated decisions with legal or similarly significant effects.
What evidence shows compliance?
A reviewer would expect: Automated decision register and review procedure.
Which frameworks map to this obligation?
It is mapped to NIST AI Risk Management Framework 1.0 GOVERN 5.x, MANAGE 4.x. These are editorial crosswalks with a stated confidence, not official mappings.
Which controls satisfy this obligation?
Decision explanation, human review and appeal route; Human oversight design and override procedure; AI interaction and use disclosure notices.
What should an organisation do in practice?
Map every significant automated decision, add a human-review route and a notice to affected people.
Cite this record
AIPolicyTracker (2026). “Apply safeguards to solely automated decisions with significant effects (ICO AI guidance)” [AIPT-OBL-0078, verified 26 September 2026 by Bhaskar Bhatt]. https://aipolicytracker.org/id/AIPT-OBL-0078 (accessed 27 October 2026). Data licensed CC BY 4.0.
Permanent id AIPT-OBL-0078: it never changes or gets reused, and its address keeps working if this page moves.
Cite the official text alongside it: Guidance on AI and data protection, Information Commissioner's Office, https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/.
BibTeX
@misc{aipolicytracker2026_applysafeguardstosolelya,
author = {{AIPolicyTracker}},
title = {{Apply safeguards to solely automated decisions with significant effects (ICO AI guidance)}},
year = {2026},
howpublished = {\url{https://aipolicytracker.org/obligations/uk-ico-automated-decision-safeguards}},
url = {https://aipolicytracker.org/obligations/uk-ico-automated-decision-safeguards},
urldate = {2026-10-27},
note = {Data licensed CC BY 4.0. Accessed 27 October 2026}
}
Change history
No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.
Similar obligations in other instruments
- Employers and employment agencies must let candidates request an alternative selection process or accommodation — NYC Local Law 144 (automated employment decision tools), New York (United States)
- Offer meaningful human review of an adverse consequential decision — Colorado ADMT law (SB 26-189), Colorado (United States)
- Respect the right to object to automated decision-making without human intervention — UAE PDPL, United Arab Emirates
- Operators of high-impact AI must ensure human management and supervision — AI Basic Act, South Korea
- Enable and assign effective human oversight — EU AI Act, European Union
- Provide routes to contest AI outcomes and seek redress — UK AI regulation framework, United Kingdom (voluntary)
- Test and monitor systems, enable human control, and be transparent with users (guardrails 4 to 6) — Australian Voluntary AI Safety Standard, Australia (voluntary)
- Determine the appropriate level of human involvement in AI decisions — Singapore Model AI Governance Framework, Singapore (voluntary)
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.