PRPO-09
Standard
Weight: 5

Fully Automated Decision-Making Systems

Plain English Explanation

This question asks whether any part of your system makes important decisions about users completely automatically, with zero human review. For example, does your software automatically reject applications, suspend accounts, or change pricing without any human checking these decisions? Regulators and customers want to know if humans can intervene when your automation makes mistakes.

Business Impact

Fully automated decision-making without human oversight violates GDPR and other privacy laws when it significantly affects users. This can lead to immediate regulatory action, fines up to 4% of global revenue, and mandatory system redesigns. Beyond compliance, customers don't trust systems that can't be appealed or reviewed by humans. Adding human oversight to critical decisions protects you legally and builds customer confidence in your fairness.

Common Pitfalls

The main pitfall is not recognizing which decisions are 'significant' - even automated account suspensions or service tier changes can qualify. Companies also mistakenly think having a support team that can reverse decisions later counts as human involvement in the decision itself.

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Question Information

Category
Privacy Policy
Question ID
PRPO-09
Version
4.1.0
Importance
Standard
Weight
5/10

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