Language you can lift into a policy
Everything on this page is written to be copied. It is offered so a compliance, legal or records team can adopt a pre-finalization review step without first having to write the wording themselves.
1. Policy clause
Adoptable as written. Replace the bracketed terms.
[Organisation] Record Defensibility Review. Before a record documenting a consequential decision about a person is finalized, the author or a reviewer shall confirm that the record can be understood, on its own terms, by a reader who was not present when the decision was made.
A record meets this standard when an independent reader can identify the conclusion, locate the evidence the conclusion rests on, follow the sequence of events, and see how the decision was reached and by whom.
Where a record is drafted with the assistance of an automated or generative system, this review is mandatory and shall be recorded as having taken place. Fluent drafting is not evidence of sufficiency.
This review is a documentation control. It does not assess whether the underlying decision was correct, lawful, or consistent with policy, and it does not replace any existing legal, HR or audit review.
2. Governance checklist
Mapped to the five review conditions. Each is a question a reviewer answers about the record in front of them. Full definitions and detection criteria are in the Codebook.
3. Vendor requirement clause
For inclusion in procurement documents where a supplier's product drafts, suggests or generates record text.
Record defensibility. Where the supplier's product drafts, suggests, or generates text that may enter a record documenting a decision about a person, the supplier shall describe in writing:
(a) what the product retains of the record text, for how long, and where it is stored;
(b) what it retains about the outcome, as distinct from the text;
(c) which subprocessors receive record text or derived results;
(d) whether the product presents any review or confidence indication to the author before the record is finalized, and what that indication is derived from;
(e) what the product does not assess.
Point (e) is the one most often omitted and the one most useful in a dispute. A supplier who can state plainly what their product does not check is easier to rely on than one who implies it checks everything.
4. Before you adopt any of it
The evidence behind this method, including what it does not establish and a pre-registered reliability criterion that was not met, is published in full at Research and Validation. Read the limits before the results. A method whose limits are not stated is not one to put in a policy.