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Automated decision-making belongs in the HR technology RFP

The Privacy Act changes reach rules, scoring and workflow as well as AI, so vendors should show where their systems shape people decisions.

Andrew Smith, Principal · 27 May 2026

I recently added automated decision-making requirements to an HR technology RFP. That sounds like an AI topic, but it's broader than that.

Changes to the Privacy Act 1988 take effect on 10 December 2026. Privacy Act-covered employers will need to explain certain uses of personal information in automated decision-making where those decisions may significantly affect a person's rights or interests.

That makes it an HCMS selection and evaluation issue.

In HR systems, decision logic sits inside ordinary product features: recruitment ranking, onboarding workflows, rostering rules, case triage, learning assignment, performance prompts, workforce alerts. Some of it is AI, but a lot of it is rules, scoring, workflow or exception handling.

The RFP question is not “does the product use AI?”, but rather whether the vendor can show where the system makes or influences a people decision, what data it uses, where a person reviews the outcome, and what record is kept.

The practical risk: an organisation selects or configures software that affects people decisions, then later finds it cannot explain the logic, show what the review point was, or align the process with its Privacy Act obligations.

For existing systems and processes, can your organisation adequately explain the automated decision-making already encoded? Pay interpretation rules are a significant example.

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