11 · Decision gate

Record the governance decision

Record a proportionate, evidence-based decision. There is no automatically correct option; the decision must follow from the evidence and say what remains uncertain.

LEGAL AND REGULATORY TOUCHPOINTS

Points to raise with specialists

FCA Consumer Duty: fair value, consumer understanding and avoiding foreseeable harm, including to customers in vulnerable circumstances.
Insurance claims-handling rules expect claims to be handled promptly and fairly.
Equality Act 2010: check for indirect discrimination where features such as postcode or speech patterns act as proxies.
UK GDPR: transparency, profiling and rules on automated decisions with significant effects, particularly if auto-decline is introduced.
Complaints may reach the Financial Ombudsman Service, which will expect clear reasons.
These are pointers for discussion, not legal advice.

Governance Decision Record

This leads your report.

Recommendation

Reasoning (150–250 words)

Balance the benefit, the harm to affected people, the evidence available and the uncertainty that remains.

Evidence the decision relies on

What did you see, not merely what you were told?

What remains uncertain

Assumptions and evidence gaps that could change the decision

Conditions, restrictions and stop conditions

What must be true for the decision to stand?

Monitoring after the decision

Measures, thresholds, review cadence and owners

Who approves

Accountable role with authority

Review date

When the decision will be revisited

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