Algorithmic transparency requirement added to digital spend controls


Tweaks made to government’s commercial guidance for departments’ spending on digital and tech projects include reiteration of new mandate for publishing data, as well as updates to investment risk metrics

Government’s digital and technology spend control guidance has been updated to demand that departments comply with transparency requirements concerning their use of algorithms.

The Algorithmic Transparency Recording Standard (ATRS) was created in 2022 and offers a consistent framework for public bodies to publish details of the algorithms used in making decisions. The publication of records was last year made mandatory for central government departments – outside of “some limited but necessary exemptions, [such as] for national security reasons”, according to guidance from the Department for Science, Innovation and Technology.

Following the mandation, almost 30 transparency releases have been published by Whitehall agencies in the last two months.

Going forward, the requirement for publication will also be enshrined in government’s digital and technology spend controls.

The latest version of the procurement guidelines, released a year ago, included the addition of two new pieces of guidance intended to work in conjunction with the core controls: the digital and data function strategic commitments; and the risk and importance framework.

The commitments have been updated this month to reinforce the need for civil service entities to meet the new transparency requirements concerning the use of automated tools.

In a new section headed “Publish a record of algorithmic tools using the ATRS”, buyers are instructed that, in order to comply with the controls, “you must publish a record using the Algorithmic Transparency Recording Standard for any algorithmic tools involved in decision making with public impact”.


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Recent updates have also been made to the risk and importance framework, a guidance document setting out criteria – covering areas such as cost, risk, and political priority – to help determine whether a project or investment is considered low, medium or high risk.

The framework now features an additional category of digital and tech spending: resourcing contracts. The new area sits alongside the four existing categorisations: digital services; platforms and common components; commodity technology and licences; and specialist technology.

“This category of spend is specifically for procuring resources to support delivery across an organisation’s projects or services – for example, cyber security professionals,” the updated guidance says.

High-risk resourcing contracts are likely to include those that are worth more than £50m or last for longer than 10 years. Lower-risk engagements, as defined by the guidelines, will encompass those lasting four years or less, and valued at less than £20m.

Across the rest of the guidelines the risk calculations have also been amended to focus on whole-life – rather than per annum – costs. For example, a high-risk digital service investment is now considered to be one that costs a total of more than £50m to develop and operate – rather than one with running costs in excess of £10m a year.

The most recent, and sixth iteration of the spend controls introduced new demands including “no automatic contract extensions”, while offering “earned autonomy” for departments that demonstrate rigorous assessment of their own projects.

Sam Trendall

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