What evidence do auditors commonly ask for on A.1.3.11 Automated decision making?

Inventory of decisions made solely by automated processing, with their effect on individuals assessed; Obligations register per jurisdiction for those decisions; Notification content disclosing the existence and logic of automated decision making; Documented human intervention route with evidence it is genuine and available; Objection route specific to automated decisions.

What is the most common gap auditors find on A.1.3.11?

Automated decisions unrecognised as such because a person nominally approves an output they never question, which is not meaningful human involvement

ISO/IEC 27701:2025 · Annex A Table A.1 PIMS controls for PII controllers

`A.1.3.11` Automated decision making

The organization must identify and address the obligations, including legal obligations, that it owes to individuals arising from decisions it makes about them based solely on automated processing of their personal data, taking account of jurisdictions that impose specific obligations where such decisions significantly affect the individual, such as notifying that automated decision making exists, allowing objection to it, or providing human intervention, and of jurisdictions where some processing may not be fully automated at all.

Source: ISO/IEC 27701:2025, A.1.3.11. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27701:2025 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Document repository

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Inventory of decisions made solely by automated processing, with their effect on individuals assessed · Policy repository / GRC workspace
Obligations register per jurisdiction for those decisions · Policy repository / GRC workspace
Notification content disclosing the existence and logic of automated decision making · Document repository
Documented human intervention route with evidence it is genuine and available · Document repository
Objection route specific to automated decisions · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Automated decisions unrecognised as such because a person nominally approves an output they never question, which is not meaningful human involvement
Inventory covering the obvious scoring engine while automated rules embedded in workflow tools go unlisted
Human intervention offered on a channel that has no authority to overturn the decision
Jurisdictions that prohibit fully automated decisions in the relevant context not identified
Notification stating that automation is used without conveying the significance to the individual

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

A.1.3.10 Handling requests · A.1.4.2 Limit collection