Welcome to the Liberate Consulting AI Compliance Scoring Framework.

As we move into 2026, the Australian regulatory landscape, specifically for AFSL holders and financial advisers, has shifted from “wait and see” to a “year of accountability”. With the Privacy Act amendments taking full effect by December 2026, your firm’s use of automated decision-making (ADM) is no longer just a technical detail; it is a core legal and conduct obligation.

This framework is designed to bridge the gap between your current AI deployment and the rigorous expectations set by ASIC and the OAIC.

Why This Assessment Matters Now

The Four Pillars of Your Assessment

To provide an accurate Compliance Score, this questionnaire evaluates your firm across four critical operational categories:

  • 1. Scope & Mapping (The Where and What): Identifying if your computer programs make or “substantially and directly” influence decisions about individuals.

  • 2. Privacy Policy (The How): Ensuring your disclosures explain in “meaningful terms” how decisions are made and what data is being used, as required by the new APP 1.7 rules.

  • 3. Governance & Accountability (The Who): Aligning your internal AI policies with s912A obligations to provide services efficiently, honestly, and fairly.

  • 4. Human Oversight (The What If): Evaluating your “explainability” and recourse methods to ensure systems are interpretable and monitored for bias or error.

While the questionnaire is visible below for transparency, completing the payment section triggers the generation of your Executive Readiness Report.

This report serves as your baseline for ASIC compliance and is a critical document for Professional Indemnity insurers. Once your report is generated, our team will schedule a high-level briefing with your leadership to interpret the findings and define the scope of your AI Strategy Workshop. We don’t just give you a score; we provide the roadmap to fix the gaps.

To secure your Executive Readiness Report and initiate the briefing process, please complete the Payment & Authorisation section in the next section below.

Name

Scope and Mapping - The Where & What

Q1.1: Have you conducted a formal audit to identify all computer programs that make—or substantially and directly assist in making—decisions about clients (e.g., credit limits, advice, or eligibility)?
Q1.2: Is there a centralised "AI/ADM Register" that lists the purpose, data inputs, and the "human-in-the-loop" status for each system?
Q1.3: Have you categorised these decisions based on "significance of impact" (e.g., access to financial products vs. internal workflow)?
Q1.4: For third-party software (CRMs, robo-advisers), have you verified with vendors if their underlying algorithms use personal data for ADM?
Q1.5: Do you have a process to review new technology procurements for ADM transparency before they are deployed?

Privacy Policy - The How

Q2.1: Does your current Privacy Policy explicitly state the kinds of personal information used by your ADM systems?
Q2.2: Does the policy explain, in plain English, how these automated decisions are made (the "logic" of the automation)?
Q2.3: Is it clearly disclosed which decisions are made solely by a computer versus those where a human provides the final sign-off?
Q2.4: Is the disclosure easily accessible to clients at the point of data collection (e.g., on a credit application form)?
Q2.5: Have you mapped out a "plain English" version of your algorithmic logic that avoids disclosing commercial trade secrets but satisfies the OAIC?

Governance and Accountability - The Who

Q3.1: Has a "Chief AI Officer" or an Accountable Official been designated to oversee AI/ADM risks within the AFSL framework?
Q3.2: Is there a formal AI Ethics or Governance Policy that specifically addresses fairness, safety, and contestability?
Q3.3: Do you conduct regular AI Impact Assessments to test for bias, errors, or unintended outcomes in your ADM tools?
Q3.4: Is there an internal incident response plan specifically for "AI failures" (e.g., algorithmic bias or data leakage)?
Q3.5: Is the Board or Senior Management briefed at least quarterly on the performance and risks of the firm’s ADM systems?

Human Oversight - The What If

Q4.1: Is there a clear, documented process for clients to request a review of an automated decision by a qualified human?
Q4.2: Are frontline staff trained to explain to a client why an automated decision was made and how they can appeal it?
Q4.3: Does the system provide "meaningful explanations" for individual outcomes (e.g., "Why was my loan declined?")?
Q4.4: Do you perform "Human-in-the-Loop" audits to ensure that human overrides of AI recommendations are consistent and fair?
Q4.5: Is the ADM system capable of being "rolled back" or turned off immediately if it begins producing harmful results?
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