Automated decision-making transparency: the inventory to run before December

Here is the awkward part. Most teams cannot produce this list today, and it is not a failure of effort. Decisions are spread across systems built at different times, by different people, for different reasons.

A scoring rule lives in a spreadsheet macro. A triage flag sits inside a case management tool a vendor set up years ago. A ranking step is buried in a hiring platform. No single person holds the full picture, so the honest first answer is often, we are not sure.

The regulator's guidance is still settling. The OAIC ran its consultation on the draft from 18 May to 15 June 2026, and intends to release the guidance by September 2026. The start date, though, does not move. It is 10 December 2026, so the sensible plan is to build your inventory now and refine the wording as the guidance lands.

You do not need a governance programme to start. You need one table with four columns, filled in for every system that scores, ranks, gates or flags a person.

• System: the tool or piece of code that makes or shapes the decision.
• Personal information in: what data about a person feeds it.
• Decision out: what the system decides or recommends.
• Who is affected: the people the decision lands on.

Two example rows show the shape. A triage flag: system, the case management tool; information in, referral details and health notes; decision out, priority level; who is affected, people waiting for a service. A candidate ranking: system, the hiring platform; information in, work history and test scores; decision out, shortlist order; who is affected, job applicants.

The inventory is your working document. The privacy policy is not. The obligation asks for the kinds of personal information used and the kinds of decisions made, not a data flow dump that no reader could follow.

So group similar systems. Describe the kinds of personal information in plain terms: contact details, health information, employment history. Describe the kinds of decisions: eligibility, prioritisation, ranking. You are giving a person a fair picture of when a machine is deciding about them, in words they can read once and understand.

Writing the list forces a second question you cannot avoid once you see it: should this decision be fully automated at all? Transparency is the trigger to review that, not just to publish.

It matters most where the stakes are high. Health Care and Social Assistance is Australia's largest and fastest-growing employing industry, projected to grow by over 12% in the five years to 2030, according to Jobs and Skills Australia. Decisions in care and eligibility shape what a person receives, so those are the rows where a human check often belongs before the outcome stands.

The work is small if you start now and larger if you wait. A short, dated plan keeps it manageable.

1. List every system that scores, ranks, gates or flags a person.
2. Fill the four columns for each one, and note anything you are unsure about.
3. Group the systems and draft the privacy policy section in plain language.
4. Mark the decisions that should have a human in the loop, and change those first.
5. Review the wording once the OAIC guidance is published, then finalise before 10 December 2026.

1. OAIC, Consultation on guidance for transparency in automated decision-making (accessed 2026-09-08)
2. Jobs and Skills Australia, Australian Jobs 2026 (accessed 2026-09-08)