ARTIFICIAL INTELLIGENCE POLICY FOR ERF MEMBER RECRUITMENT AGENCIES
Model Policy for Candidate-Facing Communications
Updated: 29th January 2026
INTRODUCTION
This model policy is intended for ERF member organisations to adopt, modify, and publish on their websites and/or provide directly to candidates. It covers transparency requirements under the EU Artificial Intelligence Act (Regulation 2024/1689), the General Data Protection Regulation (GDPR), and the Data Protection Act 2018.
Members should tailor this policy to reflect their specific AI tools and practices. Text in [square brackets] indicates where customisation is required.
IMPLEMENTATION GUIDANCE FOR ERF MEMBERS
Adopting This Policy
- Review your AI tools: Conduct an audit of all AI-assisted tools currently in use and map them against the categories in this policy
- Customise the template: Replace all bracketed text with your organisation’s specific details
- Train your staff: Ensure all recruiters understand the policy and can explain it to candidates
- Document your processes: Maintain records of human oversight and review procedures
- Publish prominently: Make the policy easily accessible on your website and include a link or reference in candidate communications
- Review regularly: Schedule at least annual reviews of the policy to ensure ongoing accuracy and compliance
Recommended Actions
| Immediate | Publish a clear, candidate‑facing AI information notice and policy, and conduct an initial audit and inventory of all AI tools used in recruitment and selection processes.
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| By 31 March 2026
| Complete due diligence on all AI vendors involved in recruitment and HR decision‑making and implement appropriate logging and documentation measures to support accountability under the GDPR and forthcoming EU AI Act obligations.
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| By 2 August 2026
| Ensure full compliance with the EU AI Act obligations applicable to deployers of high‑risk AI systems used in recruitment and employment decisions, including risk management, data governance, technical documentation, logging, transparency, human oversight, and post‑market monitoring measures.
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| Ongoing (from 2026 onwards)
| Carry out regular bias and performance audits of AI tools, provide periodic staff training on AI, data protection and non‑discrimination, and review and update AI‑related policies and records to maintain continuous compliance with the GDPR and the EU AI Act.
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This model policy is provided for guidance purposes. ERF members should seek specific legal advice on their individual circumstances and ensure the policy accurately reflects their actual practices.
Should you require any clarification on implementing this policy or wish to discuss specific AI tools your organisation is considering, please do not hesitate to contact Mary Seery Kearney, ERF DPO/Legal Advisor: mary@hrbrief.ie