CIPP/E Study Guide
IAPP Training · Module 5 - BoK II.C

Module 5 · Automated decision-making and profiling (Article 22)

Article 22 gives the data subject the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects. 'Solely' means no meaningful human intervention - a rubber-stamp human does not count. Exceptions exist where it is authorised by law, necessary for a contract, or based on explicit consent, but safeguards (human intervention, the right to express a view and to contest) must apply.

Article 22 gives the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects or similarly significant effects. 'Solely' means no meaningful human intervention; the protection is strictest for children.

Profiling is automated processing to evaluate, analyse or predict personal aspects - adware, web cookies, web beacons, digital fingerprinting. Examples with legal/significant effect: a mortgage tool auto-rejecting an applicant; auto-calculated insurance premiums. Routine behavioural ads usually have NO significant effect, but targeting gambling ads at people in financial distress, or at vulnerable people/children, can.

Article 22 exceptions and required safeguards
ExceptionSafeguard
Authorised by EU/Member State lawAs specified by that law
Necessary for a contractRight to human intervention, to express a view, to contest + info on the logic
Explicit consentRight to human intervention, to express a view, to contest + info on the logic
Certain decisions involving special-category dataAdditional conditions apply

Key terms - quick answers

What is “Article 22”?
The right not to be subject to a decision based solely on automated processing that has legal or similarly significant effects.
What is “Profiling”?
Automated processing to evaluate, analyse or predict personal aspects of a person - e.g. via cookies, web beacons or digital fingerprinting.
What is “Solely automated”?
A decision with no meaningful human intervention; a token or rubber-stamp human review does not make it non-solely-automated.