People and HR
Job ads, applications, references, surveys: the area with the greatest value and the strictest rules.
The unproblematic area
| Task | Classification |
|---|---|
| Drafting a job ad and checking its language | unproblematic |
| Answering new starter questions from policies | unproblematic |
| Checking documents for completeness | unproblematic, if completeness only |
| Draft reference from an appraisal | permissible, the line manager owns it |
| Pre-sorting applications | high risk |
| Proposing promotions | high risk |
| Assessing performance | high risk, engages co-determination |
Introduction in the unproblematic area
- 01
Start with ads and information
No personal data, immediate value, checkable result.
- 02
Involve the works council early
Not as a formality but because the agreement sets what is later permissible.
- 03
Set exclusions technically
Personnel files, sick notes and works council mail bypass the processing, not merely per the policy.
- 04
Only then consider selection
And then with full awareness of the duties.
What must be measured once selection is involved
- Accuracy and error rates separately by gender, age and, where collectable, further protected attributes.
- Selection rates per group relative to the highest. Below four fifths is an indicator of indirect disadvantage.
- Agreement with human decisions, as a baseline.
- The share of cases where a person corrected the pre-selection.
The duties under high risk
| Duty | Concretely |
|---|---|
| Human oversight | Named person with authority, time and access to the reasoning |
| Information | Applicants learn a high-risk system is in use |
| Logging | Retain the automatically generated logs |
| Input data | Ensure it is suitable and representative for the purpose |
| Fundamental rights impact assessment | For public bodies and certain private deployers |
| AI literacy | Demonstrable training of the people deploying it |
On top of that, from the GDPR: a legal basis under Art. 6, Art. 9 for special categories, information under Art. 13, and for automated individual decisions Art. 22 with a right to human intervention.
The feedback trap
A system trained on past hiring decisions learns the hiring practice of the time. Whoever was not invited then never generates data about how successful they would have been. The bias confirms itself and cannot be detected from the data alone.
Practical consequence: the earlier invitation decision is not a usable target; a later, independent success measure is. Where none exists, the project is not methodologically sound. See Bias in data.
Choosing a task in people and HR
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Selection sheet and templates: people and HR
A sheet that picks the first task out of the ones people and HR actually has, with two tested templates and the review steps for them.
Worksheet3 items