This AI Policy (“Policy”) governs the use of artificial intelligence tools and features (“AI Tools”) made available by Service Provider to its users (“Users” or “you”) as part of its products and services. This Policy supplements, and is incorporated into, the Terms of Service or, if applicable, a Master Services Agreement. By using AI Tools provided by the Service Provider, you agree to this Policy.
1. Purpose and Legal Basis
This Artificial Intelligence Governance & Responsible Use Policy ("Policy") defines the legal, technical, and organizational principles governing the design, development, deployment, and use of artificial intelligence ("AI Systems") provided by Service Provider.
This Policy is adopted to ensure compliance with:
Regulation (EU) 2024/… on Artificial Intelligence ("EU AI Act"),
Regulation (EU) 2016/679 ("GDPR"),
applicable EU and national employment, labor, and anti-discrimination laws.
2. Definitions
For the purposes of this Policy:
AI System means a machine-based system designed to generate outputs such as summaries, insights, recommendations, or search results based on given inputs.
Provider means Service Provider, acting as the provider of the AI System within the meaning of the EU AI Act.
Deployer means the customer using the AI System under its authority for recruitment or HR-related purposes, within the meaning of the EU AI Act.
3. Scope of Application
This Policy applies to all AI-enabled functionalities and services provided by Service Provider, including AI Systems used in recruitment, hiring, and HR-related contexts.
Where such systems are used for recruitment or employment-related purposes, they may qualify as high-risk AI systems within the meaning of the EU AI Act.
4. Role of Service Provider
For the purposes of the EU AI Act, Service Provider acts as the AI system provider (vendor). Service Provider is responsible for:
designing and operating AI Systems in compliance with applicable legal requirements,
implementing appropriate technical and organizational safeguards,
enabling transparency, traceability, and effective human oversight.
Users, acting as Deployers, remain solely responsible for:
defining job-specific criteria and evaluation parameters,
interpreting AI outputs,
making all final employment-related decisions,
ensuring lawful and non-discriminatory use of the AI Systems.
5. Intended Purpose and Decision-Support Nature
All AI Systems provided by Service Provider are intended exclusively as decision-support tools.
In particular:
AI Systems do not make autonomous or legally binding decisions regarding hiring, rejection, promotion, or employment outcomes.
AI outputs are generated solely based on criteria explicitly defined by the customer.
AI-generated results are advisory, non-binding, and subject to human judgment.
The AI Systems provided by Service Provider do not constitute an automated employment decision tool (AEDT) and are not intended to substantially assist or replace human discretion in employment-related decisions. AI Systems do not independently evaluate, score, rank, accept, or reject candidates and must not be used as the sole or primary basis for employment decisions.
Under no circumstances shall AI outputs be considered final or determinative decisions.
6. AI Use Cases
All AI use cases described below operate exclusively within the decision-support framework described in this Policy. In all cases, AI-generated outputs are non-binding, subject to human review, and may be modified, overridden, or disregarded by the user at any time.
6.1 Candidate Screening and CV Summarization
AI Systems summarize candidate CVs and profiles according to job-specific criteria defined by the customer. AI does not autonomously evaluate, rank, accept, or reject candidates. Summaries are intended solely to assist human users in efficiently reviewing applications.
6.2 Assessment Result Evaluation
AI Systems analyze and summarize assessment results to support interpretation by human users. AI does not determine candidate suitability, success, or employability. Final evaluation and decision-making remain exclusively with the customer.
6.3 NPS and Feedback Summarization
AI Systems summarize qualitative NPS responses and identify thematic patterns. Outputs are used exclusively for internal analytics and service improvement. No automated decisions are taken based on NPS or feedback outputs.
6.4 Semantic Search
Semantic search enables contextual retrieval of information across recruitment and HR-related datasets. The functionality does not perform evaluation, profiling, or decision-making. Semantic search operates solely as an information discovery tool.
7. Human Oversight and Override
Service Provider ensures effective human oversight by design:
All AI-generated outputs are fully visible to users.
Users may edit, override, ignore, or replace any AI-generated output.
AI outputs do not trigger automatic actions or enforce outcomes.
Human review is required prior to any hiring-related decision or action.
8. Transparency and Information Obligations
Service Provider ensures that customers are informed: when AI Systems are used,
of the intended purpose and limitations of such systems, that AI outputs are advisory and subject to human judgment. Relevant information is provided through documentation, contractual terms, and user interfaces.
9. AI Output Disclaimer
Due to the nature of artificial intelligence systems, AI-generated outputs may be incomplete, inaccurate, or contain errors. Service Provider does not warrant the accuracy or completeness of AI-generated outputs. Users remain solely responsible for verifying outputs and determining their suitability for any specific purpose.
10. Data Protection, Confidentiality, and Model Training
Service Provider does not share customer, candidate, or user data with third parties for AI processing or model training, or operates AI Systems using infrastructure fully controlled by Service Provider. Service Provider does not use public APIs.
Personal data of candidates, users, or customers is not used to train, retrain, fine-tune, or improve AI models, whether in identifiable, anonymized, or pseudonymized form. Customer data is processed solely for the purpose of providing the contracted services.
11. Data Governance and Bias Mitigation
Service Provider implements data governance measures to ensure that data processed by AI Systems is relevant, appropriate, and aligned with the intended purpose of the system.
Such measures include structured data selection and validation practices, assessment and mitigation of potential sources of bias, safeguards designed to prevent discriminatory or unlawful profiling, and continuous monitoring of AI System behavior throughout its lifecycle, including post-deployment performance and impact assessment. These measures are periodically reviewed and updated as part of AI risk management framework.
12. Accuracy, Robustness, and Security
Service Provider: defines and monitors accuracy and performance metrics, tests AI Systems against abnormal and edge-case inputs, implements safeguards against misuse or manipulation, applies industry-standard information security practices.
13. Logging, Traceability, and Monitoring
AI Systems provided by Service Provider: maintain logs of relevant inputs and outputs, enable traceability of AI-assisted processes, support audits, investigations, and regulatory inspections, are subject to post-market monitoring in accordance with the EU AI Act.
14. Prohibited Use
Customers shall not use AI Systems provided by Service Provider: for fully automated hiring or employment decisions, for discriminatory or unlawful purposes, outside the documented intended purpose of the system.
15. Review and Updates
This Policy is reviewed periodically and updated to reflect: regulatory developments, technological changes, evolving best practices in responsible AI. This Policy may be updated from time to time. Continued use of the AI Tools after changes are published constitutes acceptance of the updated Policy.
16. Contact Information
For questions regarding AI governance, compliance, or this Policy, send us email at: [email protected].