Artificial Intelligence Policy Tracker
Legal requirement Human oversight United Kingdom Guidance

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

Source-linked · linked to the official source, not yet confirmed by a reviewer (a factual check against the official source, not a legal review or legal advice)
What this label means
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— 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.
Verification policy and current standing · a factual check, not legal advice.
No change recorded as of 26 Sep 2026 · official source last checked
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 system
    Decision 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 system
    Human 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 change
    AI 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.

All 7 templates that cover it →

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Automated decision register and review procedureregister

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 mappings table
FrameworkReferenceNoteConfidence
NIST AI RMF 1.0GOVERN 5.x, MANAGE 4.xRecourse 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

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.