The Playbook

If your organisation decides things about people using software, the question this morning is not whether you are compliant. It is whether the person you believe is in the process would pass the regulator's draft test: reviewing before the decision lands, every time, with the authority and the habit of overturning it. A reviewer who has never overturned anything is not involvement, on the ICO's own draft reading.

If you work in underwriting, claims or credit, the distinction to hold is between the reading and the deciding. Every deployment we could find automates the first and keeps a person on the second. Ask which your employer is buying, and what changes if the requirement to keep you there goes.

If one of these decisions goes against you, the new rules give you four rights, all of them after the fact: to be told, to make representations, to get human intervention, and to contest. None puts a person in the room while it is decided.

And a correction we would welcome. If you know of a British insurer or lender that has moved to solely automated significant decisions since 5 February, or of a parliamentary debate on what meaningful human involvement should mean, tell us. We looked for both and could not find either, which is not the same as there being none.