StepInsight
ADM Transparency Readiness Diagnostic · with Protiviti
Readiness · Section 4

Where this decision stands against the law

One citizen-facing automated decision, walked through seven surfaces and scored against the Australian AI / ADM / privacy obligation mesh. The picture below is the readiness diagnostic — compliant, exposed, gap, or not-yet-known — against the 10 December 2026 ADM transparency deadline.

Obligation / Surface
S1Intake
S2Matching
S3Scoring
S4Human
S5Notify
S6Logging
S7Monitor
G1 ADM transparency
·
·
·
·
Gap
·
·
G2 Gov AI policy v2.0
·
·
Exp
Gap
·
·
Exp
G3 Assurance framework
·
·
·
·
·
·
Exp
G4 Administrative law
·
Gap
·
Gap
Gap
Exp
·
G5 Consistent ADM (Rec 17.1)
·
Gap
·
·
·
·
·
G6 Privacy + statutory tort
Exp
·
·
·
·
·
·
G7 Security baseline
OK
·
·
·
·
OK
·
G8 Recordkeeping (Archives)
Exp
·
·
·
·
Exp
·
G9 Anti-discrimination
·
Gap
?
·
·
·
?
G10 AI adoption practices
·
·
Exp
Gap
Exp
·
Exp
Compliant Exposed Gap Unknown — evidence not held Obligation doesn't bite this surface
The three highest-priority gaps
01 · S5 Notification
AI involvement isn't disclosed
breaches G1 (APP 1.7–1.9) · G4
Good looks like: a live disclosure in the privacy policy and at the point of decision, with reasons adequate for an ART merits review — in place before 10 Dec 2026.
02 · S2 Data matching
No screening for proxy bias
risks G5 (Rec 17.1) · G9
Good looks like: matching logic documented and tested, low-confidence matches routed to a human, and proxy-variable screening for indirect discrimination on the record.
03 · S4 The human decision
Rubber-stamp, not a decision
risks G2 · G4 · G10
Good looks like: defined review gates, overrides logged with reasons, and a named accountable decision-maker who is the person who actually reviews the output.
Readiness on 10 December 2026
Is this decision on track to be disclosable, explainable and reviewable?
Not yet. S5 disclosure is not live, and S2/S4 carry unresolved fairness and accountability exposure. Two surfaces are unknown — evidence simply isn't held — which is itself a finding.
AT RISK
[mock · teaser] Illustrative scoring on a representative decision, to show the form of the diagnostic — not a finding against a live client system. Obligation statuses current as at June 2026; orientation only, not legal advice — confirm currency before any external use. Heatmap mirrors the worked instance in PVT_adm_discovery-instrument.html.
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