United Kingdom: Information Commissioner's Office opened consultation on guidance on automated decision-making including profiling

On 31 March 2026, the Information Commissioner's Office (ICO) opened a consultation on guidance on automated decision-making, including profiling, until 29 May 2026. The guidance applies to all organisations carrying out automated decision-making, including those using in-house tools or third-party vendors, and is directed at data protection officers, compliance professionals, and technical leads. It defines automated decision-making as any decision based solely on automated processing, including profiling, that produces a legal or similarly significant effect on an individual, including decisions affecting access to credit, employment, housing, public services, or financial circumstances. Profiling, which involves analysing or predicting aspects of a person's behaviour, characteristics, or circumstances, frequently underpins automated decision-making and may involve algorithmic systems or Artificial Intelligence. The guidance requires organisations to assess whether all three triggering conditions are met, that a system is making a decision about a person, that the decision is significant, and that it is solely automated, and, where they are, to establish a lawful basis, meet additional conditions for special category data, and implement safeguards including providing information about decisions, enabling representations, ensuring human intervention, and facilitating the right to contest outcomes. It also highlights particular risks such as discriminatory outcomes, bias in training data, and heightened vulnerability for children and those in precarious circumstances.