AI Policy Template for HR & Recruiting

HR sits on the most legally sensitive AI use case there is: employment decisions. AI resume screening is already regulated (NYC's Local Law 144, Illinois' AI Video Interview Act and, since January 1, 2026, its Human Rights Act amendments on AI in employment decisions, plus EU AI Act high-risk classification), and the EEOC has made clear that discrimination law applies fully to algorithmic decisions. An HR-aware AI policy distinguishes safe drafting uses from regulated decision uses.

AI risks specific to HR and recruiting firms

• AI resume screening can produce discriminatory outcomes and is regulated in several jurisdictions
• NYC Local Law 144 requires bias audits and notices for automated employment decision tools
• Candidate and employee data in AI tools raises privacy obligations
• AI-drafted performance reviews and termination letters need human ownership

Compliance requirements your policy must address

What a complete AI policy for HR and recruiting firms includes

• Purpose, scope, and who the policy covers (employees, contractors, volunteers)
• Approved AI tools and the process for approving new ones
• Acceptable uses — and the prohibited list, including data that must never enter prompts
• Privacy-law clauses for your jurisdictions (GDPR, EU AI Act, CCPA, PIPEDA) plus EEOC / Employment Law requirements
• Human review and accountability rules for AI output
• Incident reporting, enforcement, and annual review

Frequently asked questions

Can we use AI to screen resumes?

In some places, only with bias audits and notice (NYC); in the EU, it's a high-risk AI system. The generated policy requires legal review before any AI tool influences an employment decision.

Is using ChatGPT to draft a termination letter okay?

Drafting is fine; the decision and the final text must be owned by a human, and no employee personal data should enter unapproved tools. The policy draws that line.

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