Decisions about data
Every decision to include, remove or leave out data or attributes is recorded with its reason, concern and limitation.
What clause 7.4.1 asks
Choices about data are recorded with their reasons. For every decision to keep, drop or leave out a field or a set, the record says why, and that record goes into the profile. The same applies while data is gathered, tested, used and retired. Concerns and limits found during this step are recorded too, so the file is not only a story of success.
Why it matters
The decision record is the memory of the data work. Without it, a later reader sees the data that was used but not the data that was rejected, and cannot tell whether the rejection was justified. The clause also extends the record to decommissioning, because the way data is retired can affect the people represented in it. Concerns and limitations are included so the record does not read as a success story.
What good looks like
Keep a single decision log with a row per decision: the field or data set, the action, the reason, the stakeholder effect, the owner and the date. Record the concerns and limitations in the same log, not in a separate risk register. At decommissioning, add the retirement decision and the handling of the data. Review the log at each iteration, because a decision that was right at design can be wrong after a context change.
Evidence an assessor asks for
The assessor will ask why a field that could identify a protected group was removed. The answer is either a documented reason or an unexplained gap in the record.
- Decision log Field or data set, action, reason, stakeholder effect, owner and date
- Concern and limitation log Every concern and limitation from the clause 7 tasks
- Decommissioning entry The data retirement decision and the handling record
- Review record The iterations at which the log was reviewed
Where it commonly fails
- Removed fields have no reason recorded
- Concerns are kept in a separate risk register and never linked
- The log stops at model deployment and ignores decommissioning
What to do before publication
Open the decision log before the first data extract. It is easier to record a decision when it is made.