  Important decisions that impact human lives, livelihoods, and the natural
environment are increasingly being automated. Delegating tasks to so-called
automated decision-making systems (ADMS) can improve efficiency and enable new
solutions. However, these benefits are coupled with ethical challenges. For
example, ADMS may produce discriminatory outcomes, violate individual privacy,
and undermine human self-determination. New governance mechanisms are thus
needed that help organisations design and deploy ADMS in ways that are ethical,
while enabling society to reap the full economic and social benefits of
automation. In this article, we consider the feasibility and efficacy of
ethics-based auditing (EBA) as a governance mechanism that allows organisations
to validate claims made about their ADMS. Building on previous work, we define
EBA as a structured process whereby an entity's present or past behaviour is
assessed for consistency with relevant principles or norms. We then offer three
contributions to the existing literature. First, we provide a theoretical
explanation of how EBA can contribute to good governance by promoting
procedural regularity and transparency. Second, we propose seven criteria for
how to design and implement EBA procedures successfully. Third, we identify and
discuss the conceptual, technical, social, economic, organisational, and
institutional constraints associated with EBA. We conclude that EBA should be
considered an integral component of multifaced approaches to managing the
ethical risks posed by ADMS.
