Bonus Toolkit · The AI Forward Broker
The Broker AI Decision Map
A working document for brokers. Map every AI-influenced customer decision, who owns it, and how a customer contests it. Answer a challenge on paper, inside the statutory clock.
Broker AI Decision Map
PDF · 11 pages · 7 working sections · maps to UK GDPR Articles 22A to 22D under the Data (Use and Access) Act 2025
Free to download. No form, no sign-up. Built for UK general insurance brokers. Use it alongside your DPO and compliance function. Not legal or regulatory advice.
Why this worksheet exists
The Data (Use and Access) Act 2025 replaced Article 22 of UK GDPR with new Articles 22A to 22D. The core automated decision-making rules came into force on 5 February 2026, with a statutory complaints regime following from 19 June 2026. The old rule mostly banned solely automated decisions. The new rule allows them, then attaches four duties to every significant one.
When a customer asks how an AI-influenced decision about them was made, and challenges it, you answer on paper inside the statutory clock. Not from memory. Not invented on the call.
What is inside
Seven working sections that take you from a blank page to a single file you can produce the day a customer challenges a decision or the ICO asks. Allow three to five working days to complete it properly, with your DPO, your IT lead, and the SMF who owns automated decision-making risk in the room.
01
The decision inventory
Every customer-facing decision AI touches, including the ones it only nudges. Map the decision, not the software.
02
Solely automated or human in the loop
The two tests that decide what is in scope: is it solely automated, and is it significant. A rubber-stamp does not count as involvement.
03
The four safeguards
Per in-scope decision, show where each Article 22C duty lives: information, representations, human intervention, and the right to contest.
04
Accountability
A named SMF who owns ADM risk, the roles beneath them, and the documents you should be able to produce on request.
05
The ICO and complaints file
The single file you assemble from the sections above, in the order the ICO or a challenging customer expects to read it.
06
Action log
Every gap from the sections above, with an owner, an action, a target date, and a status.
07
Self-score
Score each pillar out of 10. The first time most brokers do this, the score is lower than they expected. That is the point.
Want a working session to fill it in?
If you would rather complete this alongside your DPO and your nominated SMF, with someone who has done it before, let's have a conversation. No agenda, no pitch.