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
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 Type | Retention | Deletion Method |
|---|---|---|
| Video frames | Not stored | Processed in RAM, never written to disk |
| Audio recording | Deleted immediately | Deleted from AssemblyAI after transcription |
| Transcription text | 90 days | Automated cron deletion |
| CV and personal data | 90 days | Anonymized (name → [ERASED]) |
| AI scores | 90 days | Deleted with interview record |
| Audit logs | 3 years | EU AI Act Article 12 minimum |
| Consent records | Duration of processing + 6 years | Legal obligation (Limitation Act 1980) |
8. Legal Compliance by Jurisdiction
| Jurisdiction | Framework | Compliance Measure |
|---|---|---|
| 🇬🇧 United Kingdom | UK GDPR, Equality Act 2010, ICO AI Guidance | ICO registered (ZC112810), Article 9 explicit consent, bias detection |
| 🇪🇺 European Union | EU GDPR, EU AI Act (Annex III), DSGVO | HIGH-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 144 | Annual bias audit, public summary, candidate notification |
| 🇹🇷 Turkey | KVKK m.6 | Acik riza (explicit consent) for special category data |
| 🇩🇪 Germany | BDSG §26, BetrVG §87 | Works 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 used10. 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