When bias mitigation techniques do not fully eliminate identified bias, compensating controls are applied. Mandatory human review and enhanced monitoring are the primary compensating controls for residual bias.

Mandatory human review requires that all decisions affecting members of disadvantaged subgroups are reviewed by a human operator before being actioned. This control is most effective when the operator has access to the system’s explanation, the affected person’s complete file, and clear guidelines for when to override the system’s recommendation. The AISDP documents the subgroups subject to mandatory review, the review criteria, the operator qualifications and training, and the override rate monitoring.

Enhanced monitoring tracks fairness metrics for the disadvantaged subgroup at a higher frequency than standard post-market monitoring. Where the standard PMM cycle may review fairness metrics quarterly, enhanced monitoring may compute fairness metrics weekly or even daily, with automated alerts when metrics breach the declared thresholds. The AISDP documents the enhanced monitoring configuration: metrics tracked, frequency, alert thresholds, escalation procedures, and the responsible role.

Both controls impose operational cost. Mandatory human review creates a capacity requirement; enhanced monitoring creates a data infrastructure requirement. These costs are factored into the system’s operational planning and documented in the AISDP alongside the controls themselves.

Key outputs

• Mandatory human review specification (subgroups, criteria, operator requirements)
• Enhanced monitoring configuration
• Operational cost assessment