Profiling Needs a Human Decision Design
Recognize when profiling requires human review, transparency, and safeguards before it affects individuals.
Profiling risk lives in the decision path. A model can be useful and still create GDPR risk if its output becomes a consequential automated action. Ask what the score does Does it only inform a dashboard, or does it change access, pricing, eligibility, employment treatment, credit, support priority, or enforcement? Make human review meaningful A human rubber stamp is not a safeguard. The reviewer needs authority, context, criteria, time, and an audit trail that makes disagreement possible. Explain and challenge When a decision materially affects someone, the person should have usable information and a route to contest, correct, or escalate…
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