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Using AI for CV screening or performance ratings, allowed?

AI in HR touches the EU AI Act and GDPR. CV screening and performance rating are high-risk in 2026 with strict requirements.

Try this first

  1. 1EU AI Act: 'AI for recruitment' and 'AI for performance evaluation' are high-risk systems. That means transparency to subjects, human oversight, logging.
  2. 2Practically: AI may do a first sort or summary, a human decides. 'AI rejected you' is unacceptable both as a message and as reality.
  3. 3Tell candidates in the procedure that AI is used and in which stage. A line in your job ad and application confirmation is usually enough.
  4. 4Bias check: AI is not automatically unbiased, often the opposite. Periodic sampling of rejections across groups is wise.
  5. 5For performance ratings: AI at most as input alongside human review. A 'productivity score' from Copilot is not a disciplinary basis.

When to bring us in

A candidate or employee challenges an AI-driven decision: bring HR and a lawyer in before you respond. The AI Act is not a suggestion.

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