Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 26 NOVEMBER 2024

Market Intelligence Thought Leadership Award Winner

What Constitutes "Meaningful Information" About Automated Decision-Making?

Fieldfisher
Fieldfisher
Contributor
Fieldfisher

Fieldfisher

Fieldfisher is a European law firm with market-leading practices in many of the world’s most...

View firm profile
Explore more from Fieldfisher

Advocate General's opinion in Case C-203/22 emphasizes controllers' duty to provide clear, meaningful explanations of automated decision-making logic under GDPR, balancing data subjects' rights with trade secret protections.

United KingdomPrivacy
Hazel Grant
Hazel Grant
Anna Rawlinson
Anna Rawlinson

Have you ever asked yourself this question? Probably you have if you are a controller using automated decision-making (including profiling) and you have had to respond to data subject access requests (DSARs).

Where automated decision-making is within scope of a DSAR, the controller must provide meaningful information about the context of the automated decision-making, including the logic involved as well as the significance and consequences of the decision. The processing leading to automated decisions is technical and often complex, but as noted in regulatory guidance on automated decision-making and profiling, "complexity is no excuse for failing to provide information to the data subject".

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Ten AI Giants, One Regulator And A Lesson For Everyone Else: What The ICO’s Foundation Model Report Really Tells Us

The UK's Information Commissioner's Office has completed its supervision of major AI foundation model developers, revealing significant gaps in data protection practices and setting new expectations for legitimate interests assessments, transparency, and special category data handling. The regulator has now turned its attention to agentic AI systems, warning that autonomy is not an excuse for poor compliance and launching a call for evidence that will shape future regulatory guidance.
United KingdomPrivacy
Burges Salmon LLP
Burges Salmon LLP
Article

To Fine Or Not To Fine: EDPB Confirms Default Position In GDPR Enforcement Should Be To Fine

The European Data Protection Board has published draft guidelines proposing a fundamental shift in GDPR enforcement: a presumption that fines should be imposed for non-minor infringements, with a deliberately low bar for establishing negligence. Organizations will need to demonstrate robust compliance programs and documented decision-making to potentially avoid penalties, as regulators move from asking "should we fine?" to "can we justify not fining?"
GlobalPrivacy
Crowell & Moring LLP
Crowell & Moring LLP
Article

ICO Cookie Crackdown 2.0: The ICO’s New Storage And Access Technologies Guidance

The UK Information Commissioner's Office has finalized its guidance on storage and access technologies, expanding compliance requirements beyond traditional cookies to include tracking pixels, device fingerprinting, and web storage. Organizations must now navigate stricter consent standards and three new narrow exceptions introduced by the Data (Use and Access) Act 2025, while facing significantly increased enforcement penalties of up to £17.5 million or 4% of annual worldwide turnover.
United KingdomPrivacy
ZwillGen
ZwillGen
Article

Private CCTV, Ring Doorbells And Police Investigations: Where Does UK GDPR Draw The Line?

Domestic surveillance technology has evolved from simple security cameras to sophisticated smart systems that may inadvertently create legal obligations for homeowners. When does a Ring doorbell or CCTV system transform an ordinary citizen into a data controller subject to UK GDPR, and what are the implications of millions of private cameras forming an unregulated surveillance network?
United KingdomPrivacy
HCR Law
HCR Law
Article

The ICO's Agentic AI Call For Evidence: What You Need To Know

The UK's Information Commissioner's Office has launched a six-week consultation on agentic AI systems, examining how data protection law applies to autonomous AI agents that can make decisions and take actions with minimal human oversight. The call for evidence focuses on six critical themes including data security, transparency, accountability, automated decision-making, fairness and purpose limitation, and lawful bases for processing personal data.
United KingdomPrivacy
TLT
TLT
Article

PFAS Regulation In The UK And European Union: Autumn 2026 Overview

Fieldfisher's international legal experts share cutting-edge insights across multiple practice areas, from regulatory developments and franchise law to intellectual property, construction disputes, and corporate crisis management. This curated collection showcases thought leadership on emerging legal trends, regulatory changes, and strategic considerations affecting businesses globally in 2026 and beyond.
United KingdomCorporate/Commercial Law
Fieldfisher
Fieldfisher