The UK Information Commissioner’s Office (ICO) has published a landmark strategy to regulate artificial intelligence and biometric technologies, with a sharp focus on high-risk applications in recruitment, public services and law enforcement. The strategy sets out a path to balance innovation with accountability, reinforcing the UK’s leadership in ethical AI governance.

Central to the ICO’s plan is a forthcoming statutory Code of Practice for organisations using AI and automated decision-making (ADM) systems. This Code will define clear legal standards for the responsible deployment of AI, including algorithms used in CV screening, video interview analysis and facial recognition. It responds to growing public concern about transparency, data protection and fairness in decisions that shape lives and livelihoods.

The ICO has said the highest regulatory scrutiny will apply where risks to individuals are greatest. Recruitment is one such area, and the strategy is informed by qualitative research with job seekers from diverse backgrounds. Participants expressed frustration with a lack of transparency in AI-driven hiring—often identifying impersonal rejection emails and rapid responses as signs of automation, yet receiving little to no explanation from employers.

The study revealed strong expectations around transparency, human oversight and fair treatment. Job seekers supported limited AI use to streamline early-stage assessments but opposed fully automated final decisions. Many also highlighted the need for greater empathy and communication in hiring processes increasingly shaped by opaque technologies.

In response, the ICO is urging employers to update internal AI and ADM policies, provide clear disclosures to candidates and ensure meaningful human review in hiring decisions. Responsible use also includes bias auditing of AI tools, supplier accountability and staff training to build robust governance frameworks.

The strategy’s scope extends beyond recruitment. It sets expectations for fairness in the use of facial recognition by law enforcement and outlines principles for the development of AI foundation models. These measures form part of a broader push to embed proportionality and dignity into the digital systems underpinning public life.

Recent legislative changes have eased restrictions on ADM in certain cases, but only where strong safeguards are in place. The ICO’s approach reinforces that ethical responsibility must accompany technical advancement. Published in June 2025, the strategy is a clear signal that UK regulators intend to support AI progress without compromising rights. Through ongoing engagement and updated guidance, the ICO aims to foster a climate where trust, accountability and innovation can coexist.

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