Ongoing operations
ADM Register and Human Override
When an automated system makes decisions that significantly affect people (loan approvals, hiring screening, insurance pricing) you need a register of those decisions, a way to contest them, and a record of any human override. The ADM Register puts all of that in one place.
Transcript
GDPR Article 22 requires a register for automated decisions that affect people significantly, plus human intervention and a contest mechanism.
Each ADM record stores the logic, legal basis, profiling flag and how to contest. One row is both the Article 22 register and the contest log.
With at least one record, adm log exists becomes true, so both GDPR and UK GDPR Article 22 obligations show completed automatically.
Contest a decision from the register with a reason of at least ten characters. The row moves to appealed and awaits human review.
A reviewer records an override decision and chooses upheld or overturned. On overturned the status becomes overridden, the human intervention evidence for Article 22.
Why this is required
An automated decision that is never logged cannot be shown to have a contest mechanism, which is exactly what regulators check.
Tracking appeals and overrides on the same record keeps the decision log and the contest history together, so an auditor sees the full story without joining tables.
What EuroCompliant does
Each ADM record stores the decision title, the automated logic used, the legal basis, whether profiling is involved, and how to contest it.
From any record, a person can file an appeal with a reason. A reviewer can then record an override, either upholding or overturning the original decision.
Once at least one ADM record exists, the Article 22 obligation is satisfied.
Walking through it
Create an ADM record
Title, automated logic and contest mechanism are required. Link a system if the decision belongs to a specific AI system, or leave org-wide. Set profiling_involved and human_intervention_available explicitly.
Open /adm →Contest an automated decision
From the register, Contest / Appeal with a reason of at least 10 characters. The row moves to appealed and appeal_outcome becomes pending.
Open /adm →Record a human override
A reviewer with authority records override_decision and chooses upheld or overturned. On overturned the status becomes overridden and the evidence for Art.22(3) human intervention is complete.
Open /adm →The law
Automated individual decision-making, including profiling
Right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects, with safeguards including human intervention and contest.
Human oversight
Borrowed for the human-override element of the Art.22 contest log, the same oversight that satisfies Art.22(3).
Frequently asked
Does one ADMRecord satisfy both gdpr_22 and uk_gdpr_22?
Yes. The register is scoped to the tenant, not a jurisdiction. Any ADMRecord makes adm_log_exists true, so both the EU and UK Article 22 obligations become completed at once if they apply to your profile (processes_personal_data).
Why 10 characters for appeal_reason?
An appeal that says 'bad' is not an auditable record. The 10-character minimum ensures the reason is at least a sentence an auditor can read, without being onerous.
Related guides
GDPR & privacy
How data protection obligations run alongside the AI Act, and the parts of the GDPR that carry operational consequences.
Evidence vault & audit trail
Turning completed checklist items into artefacts a regulator can inspect, and the logging duties behind Articles 12 and 26.
Transparency and Synthetic Content Marking
Disclose AI interaction, mark synthetic content, and document deep-fake provenance.
Try it on your own systems
Everything in this guide runs in the live product. Start a free trial and follow along with your own data.
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