Legal research by PI, documents obtained by civil society organisations, and evidence from legal representatives resulted in a formal complaint to the UK Information Commissioner on 18 August 2025 regarding the Home Office's use of two automated recommendation-making tools, IPIC and EMRT. Both tools appear to be used in immigration enforcement to assist or replace human decision-making, potentially producing life-changing outcomes for migrants. The tools seem to operate without sufficient safeguards to protect privacy and meet data protection standards. Questions arise about whether the Home Office is adequately complying with the UK GDPR and the 2018 Data Protection Act. Calls for accountability are made.
On the basis of a year of legal research by PI as well as documents obtained by other civil society organisations, and evidence provided by legal representatives fighting these automated systems on behalf of their clients, on the 18th August 2025, we issued a formal complaint to the UK Information Commissioner (ICO) regarding the UK Home Office's use of two 'automated recommendation-making tools' (ARMTs), the Identify and Prioritise Immigration Cases tool (IPIC) and the Electronic Monitoring Review Tool (EMRT).
Both these tools appear to being used in immigration enforcement operations to assist or even replace human decision-making in ways that could lead to life-changing outcomes for migrants, seemingly without sufficient safeguards to protect the right to privacy and meet data protection standards. This raises concerns as to whether the Home Office is adequately complying with the UK General Data Protection Regulation (GDPR) and 2018 Data Protection Act, which both regulate the processing of personal data in the UK.
#automated-decision-making #immigration-enforcement #data-protection-gdpr #home-office-accountability
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