Acclivitas ("we", "us", "our") uses AI-supported tools as part of certain executive search and recruitment activities. This notice explains what these tools do, how they affect you if you are a candidate, and what rights you have under the General Data Protection Regulation (GDPR) and the EU Artificial Intelligence Act ("EU AI Act"). The tools used support the following legal requirements: Art. 28 DSGVO, DPA, EU-hosting, no use of data for training, or exceed them: ISO 27001 certified, SOC 2 Type II certified. This notice supplements our general Privacy Policy and applies specifically to the use of AI in our search and selection process.
1. What AI tools we use and why
As part of our recruitment process, we use AI-supported software to help analyse CVs and assess candidate profiles against role requirements. This may include functions such as:
- Structuring and summarising information from CV, application documents and meeting notes for supporting evaluation
- Matching candidate profiles against the requirements of a specific role
- Highlighting relevant experience, skills, or qualifications for a consultant's review
- Drafting communication
These tools are used to support - not replace - the judgment of our consultants. They help our team work through large volumes of information more efficiently, but they do not make hiring or shortlisting decisions on their own.
2. No decision is made by AI alone
No decision that produces legal effects or similarly affects you — such as whether you are shortlisted, presented to a client, or rejected from a search - is made solely by an automated system. Every AI-assisted output is reviewed by a qualified consultant before it is used in any step of the process. A human always makes the final assessment (human in the loop). This reflects our obligations under Article 22 GDPR (right not to be subject to
a decision based solely on automated processing) and Article 26(2) of the EU AI Act (requirement for human oversight of AI systems).
3. Why this falls under the EU AI Act
As a deployer of AI systems used to analyse, filter, or evaluate job applications, we are required to:
- Inform you that an AI system may be used in a process that concerns you (Article 26(11))
- Ensure the system is used under competent human oversight (Article 26(2))
- Ensure the data used by the system is relevant and appropriate to its purpose (Article 26(4))
- Keep records of the system's use for accountability purposes (Article 26(6))
This notice, together with any information provided to you individually during a specific search process, is intended to meet this transparency obligation.
4. Your rights
Because AI plays a role in our process, you have the following rights in relation to it:
- Right to human review. You may ask a consultant to explain how your application was assessed and to review any AI-assisted output that concerned you, at any time — you do not need to wait for the process to conclude.
- Right to an explanation. Where a decision that significantly affects you is based on the output of an AI system, you have the right to receive a clear and meaningful explanation of the role the AI system played and the main factors behind the outcome (Article 86 of the EU AI Act).
- Your GDPR rights. As with any processing of your personal data, you also have the right to access, correct, or request erasure of your data, to object to processing, and to lodge a complaint with a supervisory authority. These rights are described in full in our Privacy Policy. To exercise any of these rights, contact us at privacy@acclivitas.com.
5. What data is used and how long we keep it
The AI tools we use process the information you provide to us directly - typically your CV, application documents, and any information shared in interviews or profile discussions. We retain candidate data, including any AI-assisted assessment notes, so that we may consider you for suitable future opportunities. You may ask us to delete your data at any time by contacting us using the details above.
6. Safeguards we apply
- All AI tools used in our process are evaluated before deployment for their intended purpose, data handling practices, and alignment with GDPR and EU AI Act requirements.
- Access to AI-assisted outputs is limited to consultants directly involved in the relevant search.
- We do not use AI to infer sensitive characteristics (such as health, ethnicity, religion, or trade union membership) as part of candidate evaluation.
- We periodically review our AI-supported processes to check for consistency, fairness, and accuracy.
7. Questions or concerns
If you have questions about how AI is used in our process, or you would like to raise a concern, please contact us at privacy@acclivitas.com. You also have the right to lodge a complaint with your competent data protection supervisory authority - in Germany, the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) or the relevant state authority (Landesdatenschutzbehörde) for your region.
This notice is provided for transparency purposes and does not constitute legal advice.
