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AI System Transparency Report

EU AI Act Article 13 — Transparency Requirements for High-Risk AI Systems

This report covers HumanBaseIQ only — the one system we classify as high-risk under Annex III. For every other AI system we run, and how each is classified, see the company-wide AI Transparency Disclosure.

Last updated: 18 July 2026 | Version 2.0

1. AI System Identification

System NameHumanBaseIQ — AI-Powered Recruitment Platform
ProviderSummitBridge Horizon Ltd (Companies House: 16419201)
Risk ClassificationHIGH-RISK — EU AI Act Annex III, Area 4: AI systems used in the recruitment or selection of natural persons (Article 6 + Annex III). Article 5 prohibited practices (emotion / facial inference in the workplace) are NOT performed by this system.
EU AI Act ArticlesArticle 6 (Classification), Article 9 (Risk Management), Article 11 (Technical Documentation), Article 12 (Record-Keeping), Article 13 (Transparency), Article 14 (Human Oversight), Article 50 (limited-risk transparency for voice/video add-ons)
GDPR ClassificationPersonal Data Processing (Article 6) — candidate identifiers, transcripts, and voluntary opt-in audio/video recordings. No biometric template extraction, no emotional analysis.
ICO RegistrationZC112810
Data Protection Officer[email protected]

2. Intended Purpose

HumanBaseIQ assists employers in the recruitment process by providing AI-powered analysis of candidate applications. The system provides decision-support information only. No hiring decision is made automatically by the AI system. A qualified human reviewer must always make the final decision.

AI capabilities:

  • CV parsing and structured data extraction
  • Skills-based candidate-to-role matching
  • Text-based AI interview (20 role-specific questions)
  • Voice analysis (limited-risk): audio recording → transcript only; no paralinguistic/emotional-tone inference
  • Video analysis (limited-risk): video recording → transcript only; no facial-expression, body-language, or emotion inference
  • Bias detection: automated flagging of potentially discriminatory wording in transcripts

3. Data Processing Methods

3.1 Text Analysis (CV + Interview Answers)

Processed by Claude AI (Anthropic, US-based). Text is sent via API, processed, and response returned. No text is retained by the AI provider beyond the API call.

3.2 Voice Analysis (Opt-in)

Processed by AssemblyAI (US-based, GDPR DPA in place). Audio is uploaded for transcription and sentiment analysis. PII is automatically redacted (names, emails, phone numbers, dates of birth). Transcripts and audio are deleted from AssemblyAI servers immediately after analysis.

3.3 Video Analysis (Opt-in) — Limited-Risk (Article 50)

Video recording with explicit candidate consent. Audio track is transcribed (AssemblyAI, deleted after transcription). The video stream is retained encrypted (AES-256) for the data-retention period configured by the employer, and is available only for human reviewer playback alongside the transcript. No AI analysis is performed on the video stream itself.

What this product does NOT do (Article 5 safeguard):

  • No facial-expression recognition
  • No emotional-state inference
  • No body-language or eye-contact scoring
  • No paralinguistic / stress / confidence derivation
  • No biometric template extraction, no identity matching

Following the May 2026 pivot, all decision-support output is derived from the transcript only. Workplace emotion inference is prohibited under EU AI Act Article 5(1)(f); HumanBaseIQ is engineered so this prohibition does not apply.

4. Human Oversight (Article 14)

  • All AI scores are capped at 85/100 — no candidate can be fully scored without human review
  • Bias flags trigger mandatory human review before any decision
  • The employer's HR team makes all final decisions; the AI provides supporting data only
  • Candidates who refuse biometric analysis are not penalised — text-only interview is always available
  • Employers can override or disregard any AI recommendation

5. Bias Mitigation & Fairness

  • Automated detection of sensitive topics: age, family status, religion, nationality, disability, marital status, children
  • Any mention of protected characteristics triggers mandatory human review
  • Scoring algorithm does not use protected characteristics as inputs
  • Quarterly bias audit available (NYC Local Law 144 compliant)
  • UK Equality Act 2010 Schedule 19 compliance embedded
  • Disparate impact analysis available for employer review

6. Candidate Rights

Right to Information

Full disclosure of AI involvement before any analysis begins. This page serves as the Article 13 transparency notice.

Right to Opt-Out

Candidates may refuse voice and/or video analysis without penalty. Text-only interview is always available as an alternative.

Right to Erasure

All personal data deleted within 72 hours of request. Contact [email protected] or use the automated erasure form.

Right to Explanation

Candidates may request an explanation of how their AI score was calculated, including which factors contributed positively or negatively.

Right to Contest

Candidates may challenge AI-assisted decisions. The employer must review the challenge with a qualified human who was not involved in the original decision.

Right to Human Decision

Candidates may request that their application be assessed entirely by humans, without AI involvement.

7. Data Retention

Data TypeRetentionDeletion Method
Video framesNot storedProcessed in RAM, never written to disk
Audio recordingDeleted immediatelyDeleted from AssemblyAI after transcription
Transcription text90 daysAutomated cron deletion
CV and personal data90 daysAnonymized (name → [ERASED])
AI scores90 daysDeleted with interview record
Audit logs3 yearsEU AI Act Article 12 minimum
Consent recordsDuration of processing + 6 yearsLegal obligation (Limitation Act 1980)

8. Legal Compliance by Jurisdiction

JurisdictionFrameworkCompliance Measure
🇬🇧 United KingdomUK GDPR, Equality Act 2010, ICO AI GuidanceICO registered (ZC112810), Article 9 explicit consent, bias detection
🇪🇺 European UnionEU GDPR, EU AI Act (Annex III), DSGVOHIGH-RISK classification, Article 13 notice (this page), SCCs for data transfers
🇺🇸 USA (Illinois)BIPA (740 ILCS 14)Written informed consent before biometric collection, data destruction policy
🇺🇸 USA (New York City)NYC Local Law 144Annual bias audit, public summary, candidate notification
🇹🇷 TurkeyKVKK m.6Acik riza (explicit consent) for special category data
🇩🇪 GermanyBDSG §26, BetrVG §87Works council notification support, strict purpose limitation

9. Technical Architecture

Video Upload (encrypted TLS 1.3)
  │
  ├─→ Face Analysis (on-server, self-hosted)
  │     • face-api.js + TensorFlow.js
  │     • 7 emotion categories
  │     • 68 facial landmarks → eye contact
  │     • Frames: RAM only, never persisted
  │
  ├─→ Voice Analysis (AssemblyAI, DPA)
  │     • PII auto-redacted before analysis
  │     • Transcript + audio deleted post-analysis
  │     • Sentiment, pace, pause patterns
  │
  ├─→ Transcript Analysis (Anthropic Claude, via AssemblyAI LeMUR)
  │     • Normal path for every interview
  │
  ├─→ [FALLBACK ONLY] OpenRouter → Google Gemini 2.5 Flash
  │     • Fires only if the analysis above is unavailable
  │     • First 6,000 characters of transcript sent
  │     • Degraded output: no per-segment sentiment or pace
  │     • Routed with data_collection: deny — providers that
  │       retain or train on prompts are excluded
  │
  └─→ Scoring Engine (on-server)
        • Max score: 85/100 (human review enforced)
        • Bias flags → mandatory review
        • No protected characteristics used

10. Contact & Complaints

Data Controller: SummitBridge Horizon Ltd

Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ

Companies House: 16419201

ICO Registration: ZC112810

DPO Email: [email protected]

General: [email protected]

Supervisory Authority: Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
ico.org.uk | 0303 123 1113

This transparency report is published in accordance with EU AI Act Article 13 and is updated whenever material changes are made to the AI system. Previous versions are available upon request.

Document reference: SBH-AIT-2026-002 | Classification: Public