SC-AI-027 · Human oversight

Right to contest and human review for individuals

Medium effortCovered by ISO 27001: New for AISatisfies 6 obligations in 5 policies

What it means

  • A person affected by an AI-driven outcome can easily ask for a human to look at it again, and can submit facts the AI may have missed.
  • The human reviewer can change the outcome, and the person is told the result.
  • Customers can switch from an AI channel to a human at any point in regulated journeys.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001. SOC 2 P5.2 (correcting personal information) is a partial analogue.

Why it matters

  • RBI FREE-AI expects customers to always be offered a switch to a human when dealing with AI.
  • Wrong automated decisions (blocked accounts, rejected claims, failed KYC) cause real harm and complaints that escalate to the RBI Ombudsman.
  • Laws abroad (for example EU GDPR Article 22 and the EU AI Act) give individuals similar rights; customers of Indian SaaS exporters will ask for it.

Checklist

  1. Identify AI outcomes that significantly affect individuals (credit, insurance, employment, account restrictions, KYC).
  2. Add a clear "request human review" link or option in the notice of outcome and in the AI chat or voice flow.
  3. Define who reviews, required skill, and a target turnaround (for example 7 working days, faster for account blocks).
  4. Give reviewers the full case: inputs, model output, explanation and the person's new information (SC-AI-024 Explain AI-assisted decisions).
  5. Make sure the reviewer is not just re-running the same model.
  6. Tell the person the outcome and the reasons, and point to the grievance route if they remain unhappy (SC-AI-028 Customer grievance redressal for AI).
  7. Track review volumes, reversal rates and turnaround; feed reversal patterns into model improvement (SC-AI-020 Performance monitoring and drift detection).

Evidence examples

  • Screenshots of the "request human review" option in notices and chat flows.
  • Human review SOP with roles and turnaround targets.
  • Case log showing requests, reviewer, outcome, reasons and dates.
  • Monthly report of reversal rate and turnaround versus target.
  • Test record showing the AI-to-human switch works in each channel.

Common pitfalls

  • Review request hidden behind several menus or only available by post.
  • Reviewer sees only the AI score and confirms it.
  • No feedback loop, so the same error repeats for thousands of customers.
  • Human handoff available only during office hours with no notice of when to expect contact.

Satisfies

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • A.8.2 system documentation and information for users
  • A.8.3 external reporting
  • A.9.2 processes for responsible use

ISO/IEC 27001

No direct equivalent

SOC 2

  • CC2.3
  • P5.2

Key takeaways

  • Make asking for a human review easy, at the point the outcome is shown.
  • The reviewer must have the full case and the power to change the result.
  • Use reversals as a signal to fix the model.

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