EU-KI-Gesetz-Dokumentation
für KI im Recruiting

2. System Description

This technical documentation has been prepared by Example HR Tech sp. z o.o. as the provider of the artificial intelligence system RecruitAI Pro in order to demonstrate compliance with the requirements of Article 11 and Annex IV of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (the "AI Act"). This documentation is kept up to date throughout the system's lifecycle and made available to competent market surveillance authorities upon their reasoned request in accordance with Article 18(1) of the AI Act.

2.1 Intended Purpose

The system RecruitAI Pro is intended for application in the area of recruitment and selection of natural persons. The detailed scope of the intended purpose includes: automated analysis of candidate applications, preliminary screening of submissions, ranking of professional profiles, and generation of structured reports for recruiters.

In accordance with Article 3(12) of the AI Act, "intended purpose" means the use for which an AI system is intended by the provider, including the specific context and conditions of use, as specified in the information supplied by the provider in the instructions for use, promotional or sales materials and statements, as well as in the technical documentation.

The provider explicitly states that the system is NOT intended for:

• making fully automated final recruitment decisions without human involvement,
• profiling candidates based on protected characteristics within the meaning of Article 9 GDPR without an explicit legal basis,
• assessing employees in a manner prohibited under Article 5(1)(c) of the AI Act (social scoring),
• applications outside the European Economic Area without a separate conformity assessment.

2.2 System Interaction and Integration

The system RecruitAI Pro operates as a SaaS (Software as a Service). It interacts with the following external and internal components: deployer's HRIS/ATS systems, authentication modules, candidate databases, and reporting interfaces. System boundaries have been clearly defined and cover only components controlled by the provider; third-party integrations remain outside the scope of this documentation and require a separate risk assessment by the deployer.

The system architecture is based on natural language processing (NLP)-based machine learning. Technical details concerning model version, training parameters, and computing infrastructure are contained in technical annexes to this document and are subject to version control in accordance with the quality management system described in Section 7.

2.3 Deployment and Distribution

The system is made available to deployers on the European Union market, with particular focus on the Polish market. Distribution takes place under the SaaS model. Each deployment is preceded by the conclusion of an agreement containing provisions on the allocation of responsibilities in accordance with Articles 25 and 26 of the AI Act.

The provider maintains a register of all deployments together with information allowing the identification of each instance of the system, which enables the fulfilment of obligations under Article 20 (corrective actions) and Article 73 (reporting of serious incidents) of the AI Act.

2.4 User Interface

The user interface has been designed in accordance with the transparency principles arising from Article 13 of the AI Act. End users (candidates) are informed of the fact that they are interacting with an AI system, and persons interacting with the system's outputs (recruiters, HR managers) receive indications regarding the level of confidence, system limitations, and the necessity of verification