Module · AI on people is high-risk

The HR Team AI Check

When your HR team points AI at candidates and employees, it is not automating a workflow, it is making decisions about people under the strictest tier of the EU AI Act. Screening, ranking and assessment tools sit in the Act's high-risk class, with duties that attach whether or not you noticed. This module checks the five things that decide whether your people processes are defensible: whether you test the screening for bias, whether candidates are told, where a human actually decides, what employee data your tools ingest, and whether the works council was in the room before any of it went live.

Question 1 of 5 · Screening tested for bias

Do you test your AI screening for bias against protected groups, on your own data?

An AI trained on who you hired before will reproduce who you hired before, including the patterns you would never write into a policy. A vendor's fairness certificate is not evidence about your roles and your applicant pool. Under the AI Act this testing is not optional diligence, it is a documented duty for high-risk hiring tools.

Question 2 of 5 · Candidates are told

Are candidates told when AI is used to screen or assess them?

People have a right to know when a machine is judging their application, and increasingly a right to a human review and an explanation. Silent AI screening is the fastest route to a complaint, a regulator, and a headline. Disclosure costs you a sentence; the alternative costs you the story.

Question 3 of 5 · A human decides

Is there a point where a human actually makes the hiring decision, not just rubber-stamps the AI?

Meaningful human oversight is a legal requirement for high-risk hiring AI, but a human who always agrees with the ranking is oversight in name only. The question is whether your recruiters have the information, the authority and the habit to overrule the machine, and whether they ever do.

Question 4 of 5 · Employee data stays bounded

Do you control what employee data goes into AI tools, and where it ends up?

Performance notes, health-related absences, salary, disciplinary records: the moment this data flows into a general AI tool, you have lost the boundary that data-protection law demands you keep. HR handles the most sensitive category of employee information there is, and a convenient chatbot is the easiest place to leak it.

Question 5 of 5 · Works council involved

Was the works council involved before you deployed AI that affects employees?

In Germany and much of the DACH region, introducing AI tools that monitor or assess staff triggers the works council's co-determination rights. Involving the Betriebsrat early is not a courtesy, it is a precondition: skip it and a deployment can be blocked, unwound, or dragged before a labour court after you have already rolled it out.

For the statistics · one click each

Three questions for the public picture

These do not affect your score. They feed the anonymised, aggregated statistics; groups under 8 respondents are never shown.

Where does your HR team already use AI on people?

Not yet
Sourcing and outreach
Screening and ranking
Assessment or scoring
Across the employee lifecycle

Have you tested your hiring AI for bias on your own data?

No
Only vendor assurances
Once
Regularly
No hiring AI in use

Was the works council involved before your employee-facing AI went live?

Not involved
Told afterwards
Consulted before launch
Formal agreement in place
No works council exists

Your context

Used to calibrate the report. Company size and sector remain in the anonymized dataset; your email does not.