Submission published: consultation on automated decision-making

We have published our response to the consultation on automated decision-making in public administration, in full and as submitted.

We supported the proposals on registration, notification and appeal. We opposed the exemption for systems described as decision-support rather than decision-making, on the grounds that the distinction will not survive contact with practice. And we identified the absence of any capacity provision for the supervising authority as the draft’s most consequential feature.

We publish our submissions whether or not our advice is taken. Where it is not, we will say so.