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Telling people when AI decides about them

Transparency notices · DIFC Reg 10 §10.2.2(a) (notice on first use); §10.2.2(b) (required contents)

Reviewed 18 Sep 2026

Forward to your CISO

What the rule is

When an automated system makes or shapes a decision about a person, you must tell that person. You do this through a Transparency Notice. A Transparency Notice is a clear, plain message that explains what is happening.

The notice must be comprehensive, true and plain. The goal is that the affected person can actually understand it, not just receive it, so write it in the language your users read. The DIFC primary sources do not themselves impose an Arabic version; if you serve Arabic-speaking data subjects, treat an Arabic version as a comprehension question and take your own advice on any language requirement outside these instruments.

A good notice covers a few key points:

  • That automated processing is being used.
  • What the processing is for.
  • The main logic behind the decision, in plain terms.
  • The right to ask a human to review the decision.

That last point matters most. Under the DIFC Data Protection Law, people have a right to an explanation and to human review. The notice is how they learn that right exists.

Why it matters

People cannot challenge a decision they do not understand. A missing or confusing notice quietly removes their ability to push back.

The DIFC Commissioner can review your notices during an inspection. Vague notices, and notices that omit the required contents, are a common failing. Where someone suffers damage by reason of a contravention of the Law, DPL Article 64A gives them the right to apply to the DIFC Court for compensation.

How to comply

  1. Identify every system that makes automated decisions about people.
  2. Write a plain-English notice for each one.
  3. Show it on initial use of, or access to, the system, not buried in a policy page.
  4. State clearly the right to ask a human to review the decision.
  5. Show the notice at the right moment, not buried in fine print.

How regulation10.ae helps

regulation10.ae gives you bilingual Transparency Notice templates that name the automated processing and the right to human review. It links each notice to the system it describes, so your notices stay accurate as systems change. You keep a versioned copy as evidence for assessment.

Check your notices with the free readiness assessment, or see our plans.

Audit-ready, not certification. This guide helps you produce evidence for assessment. Certification may only be issued by an Accredited Certification Body or by the Commissioner, if the Commissioner establishes a certification scheme. Confirm your specific obligations with counsel.

One guide answered your question. Talk to us about the rest.

Telling people when AI decides about them, regulation10.ae