AI compliance/AI in HR
Vertical
Audit of the AI systems used in human resources.
Tools that screen applications, score candidates or match profiles are classed as high risk under the Act. This audit records the ones you use, measures their risks and sets out what remains to be done, under the AI Act, GDPR and employment law.
- Duration
- 4 to 6 weeks
- Access required
- None to the vendor’s model
- Frameworks
- AI Act, GDPR, employment law
- Output
- Formal opinion and roadmap
You are a deployer, with duties of your own
The tool comes from a vendor, but the company using it to recruit or to assess answers for that use: human oversight, relevance of input data, retention of logs, information to workers. The contract signed with the vendor does not transfer those duties.
A closed tool can still be audited
We submit counterfactual CVs to the tool, identical but for one characteristic, and measure what changes in the outcome. The method runs black box: it needs no access to the vendor’s model.
Scope
Three bodies of rules, one audit.
A single recruitment tool falls under AI regulation, data protection and employment law at once. We examine them together, across the whole candidate and employee journey.
Worth checking
Features added by the vendor. An applicant tracking tool can gain a ranking or scoring feature through an update. The inventory picks these up, including the ones nobody asked for.
How it runs
Six steps, from inventory to opinion.
- ScopingThe recruitment and people-management stages covered, the tools in scope, and the people involved: HR, HRIS, legal, data protection.
- Inventory and qualificationEach AI system is recorded, classified by risk tier and assigned a deployer or provider role.
- Obligations reviewDeployer obligations are mapped one by one, together with the impact assessments and the employment law review.
- TestingQuantitative tests of differences in treatment, counterfactual auditing of the black-box tool, and a search for proxy variables.
- Vendor reviewWhat the vendor documents, what it commits to by contract, and what stays with you.
- Opinion and action planA formal opinion, the residual-risk register with its compensating controls, and a prioritised roadmap.
Deliverables
What you receive.
Who the HR audit is for
HR leaders and HRIS leads, most often deployers of tools built by a vendor, together with the legal functions and data protection officers who work alongside them.
Around the HR audit
A vertical of the audit, not a separate exercise.
Next step
Scope an HR audit.
Tell us which AI tools are used in your recruitment and talent management. We will come back with a proposed scope, a duration and a fixed fee.
