The guidance update and the underlying data
The Information Commissioner’s Office updated its AI and data protection guidance on 15 March 2023, including clarification on fairness requested by industry. The publication addressed organisations developing or using AI systems that process personal information. It was relevant to recruitment because candidate records and screening decisions can be part of those systems.
This was guidance about responsible processing, not a certificate that any particular recruitment product was safe. The live guidance now carries a notice about subsequent legal changes. This article therefore describes the 2023 development and draws operational lessons from it; it does not present the historical text as a complete statement of today’s law.
What history does the tool inherit?
Historical recruitment data can contain inconsistent job titles, incomplete employment histories and decisions made under criteria nobody recorded. Feeding that material into an automated workflow can make poor assumptions harder to see. Before testing a tool, a team should identify which fields are reliable and which records need clarification or exclusion.
Fairness also needs an accountable review process. A recruiter should be able to explain the evidence used for a shortlist, identify the person authorised to question a recommendation and give candidates a route to raise concerns. Review should consider accessibility and missing information, rather than assuming that a low score is a complete account of suitability.
Make records and human review easier to examine
Key Med can help prepare cleaner candidate databases and more consistent administrative workflows. An agreed project might include duplicate detection, field standardisation, documented screening criteria and a register of unresolved data issues. Access should be limited to authorised records, with retention and deletion instructions set by the client rather than improvised by individual users.
For a pilot, select one bounded task and compare its output with an independently reviewed sample. Record exceptions, reasons for overrides and changes to the underlying data. Key Med’s role can support that evidence trail and coordination; the employer and its specialists retain responsibility for assessing the tool, its lawful use and the hiring decision.
The source material
- Guidance on AI and data protection: March 2023 update ↗Information Commissioner's Office · 2023-03-15
Retrospective briefing · Published 4 November 2026. Historical figures and measures describe their period; consult current official guidance before acting. This article provides operational context. Legal, immigration, clinical and financial decisions need the responsible organisation’s qualified advisers.
