Purpose

This playbook provides straightforward guidance on the use of Artificial Intelligence (“AI”) in HR processes and the employees’ rights.

TITLE: AI DATA PROTECTION PLAYBOOK	POLICY OWNER: [insert department name]
ELECTIVE DATE: [insert date]	LAST REVIEW DATE: [insert date]
POLICY OBJECTIVE: To outline the principles and guidelines for the use of employees’ data with Artificial Intelligence (AI) within [insert Company name]. This playbook aims to ensure that employee’s data is used in a manner that is ethical, transparent, and aligned with [insert Company name] values and standards.

Obligations at a Glance

When processing employees personal data, the Company respects the fundamental principles of data protection (such as lawfulness, good faith, transparency, purpose limitation, proportionality, retention period, security, confidentiality, etc.)

Transparency: employees have the right to know how their personal data are being processed, and when AI is used in HR decisions affecting them (Employees Data Privacy Notice)
Accuracy: the Company has to keep correct personal information and rectify any inaccurate information
Automated individual decision-making:
- The Company informs employees if they are subject to a decision based solely on automated processing with significant effects
- The Company must give employees the right to obtain human intervention, to express their point of view and to contest the decision
- The Company has to explain how an automated decision was made if employees ask
Objection: employees, in some circumstances, can object to the processing of their personal data

How we might use AI with Employee’s Data

HR Function	How AI might be used	What data might be processed
Recruitment	Resume screening, interview analysis	Work history, education, skills, video/audio recordings
Performance	Productivity metrics, feedback analysis	Work outputs, communication patterns, peer feedback
L&D	Skill gap identification, content recommendations	Skills profile, learning history, career goals
Benefits	Usage pattern analysis, personalised recommendations	Health information, benefits selections, usage patterns
Workplace Planning	Turnover prediction, capacity forecasting	Tenure, performance history, team composition

How does the Company assess the use of AI in HR?

When the Company uses AI to improve HR processes and the employees’ experience we ask ourselves the following questions:

Is it transparent?

Have we told the relevant persons that AI is being used?
Have we told the relevant persons what personal data is being processed?

Is it accurate?
Is the personal data being used correct and up-to-date?Is it fair?
- Could the HR AI system produce biased outcomes?
- Does it consider the relevant person’s specific circumstances?
Is it secure?
- Is sensitive personal data involved?
- Are appropriate security measures in place?

Purpose

Obligations at a Glance

How we might use AI with Employee’s Data

Employees’ Rights