AI Policy

How We Use AI in Our Recruitment Services

Effective Date: 23/7/2026 | Last Reviewed: 07/8/2026

1. Our Commitment to You

At ICE Jobs, we are committed to providing our recruitment services in a fair, transparent manner, and in full compliance with all relevant laws, including the EU Artificial Intelligence Act and the General Data Protection Regulation (GDPR).

We believe that technology should support, not replace, human judgement in recruitment decisions. This policy outlines how we utilise artificial intelligence (AI) tools in our recruitment processes, the safeguards we have in place, and your rights as a candidate.

Where ICE Jobs recruiters work within a client-owned recruitment system, the client remains responsible for the configuration and governance of that system. ICE Jobs recruiters will follow agreed client procedures and will not use client system AI functionality to make autonomous recruitment decisions unless this has been specifically assessed, approved and documented.

2. What Is Artificial Intelligence?

For the purposes of this policy, "artificial intelligence" or "AI" refers to software systems that can, given a set of objectives, produce outputs such as predictions, recommendations, or decisions that may impact recruitment processes. This includes:

• Automated CV screening and parsing tools
• Candidate matching algorithms
• Skills assessment platforms

3. How We Use AI in Recruitment

We may use AI tools to assist with the following activities:

3.1 Administrative and Efficiency Tasks

AI Application	Purpose	Human Oversight
CV parsing	Extracting information from CVs to populate our database accurately	All parsed data is reviewed by a recruiter before use
Automated acknowledgements	Confirming receipt of applications	Recruiters monitor all communications
Chatbot enquiries	Answering frequently asked questions about roles or processes	Complex queries are escalated to a human recruiter

 

3.2 Candidate Matching and Screening

AI Application	Purpose	Human Oversight
Skills matching	Identifying potential matches between candidate profiles and job requirements	All matches are reviewed by a qualified recruiter before any candidate is contacted or shortlisted
Keyword identification	Highlighting relevant experience and qualifications	Recruiters assess the full application, not just highlighted keywords
Ranking assistance	Ordering applications to assist recruiter review	Rankings are advisory only; recruiters make all shortlisting decisions

 

4. What AI Is Not Used For

We do not use AI to make final recruitment decisions.

The following decisions are always made by qualified human recruiters and/or our clients:

• Shortlisting decisions: A human recruiter reviews all applications before determining who progresses to an interview. AI might assist in organising or highlighting applications, but the final decision to shortlist or reject is made by a person.
• Interview outcomes: All interview assessments are conducted and evaluated by human beings.
• Job offers: Decisions to offer employment are made by our clients, supported by our professional recommendations, not by automated systems.
• Rejection decisions: No candidate is rejected solely by an automated process. Where AI tools flag potential mismatches, a human recruiter reviews the application before any decision is communicated.

5. Why You Might Not Be Shortlisted

We understand that not being shortlisted for an interview can be disappointing. There are many reasons why this might occur, including:

• The role has attracted a high volume of applications from candidates whose experience more closely matches the specific requirements
• Essential criteria specified by the client, such as qualifications, certifications, or years of experience, were not evidenced in your application
• The role has been filled or withdrawn before your application could be fully considered
• Location, availability, or salary expectations did not align with the role requirements

Important: Where AI tools are used to assist in organising or reviewing applications, a human recruiter will always make the final determination about whether to progress your application. You will never be rejected solely because an algorithm has made that decision.

6. Human Oversight and Review

In accordance with the EU AI Act and GDPR requirements, we maintain meaningful human oversight of all AI-assisted processes:

6.1 Qualified Human Review

• All AI outputs that may affect your candidacy are reviewed by trained recruitment professionals before any action is taken
• Our recruiters are trained to identify and correct potential errors or biases in AI-generated recommendations
• Recruiters have the authority to override any AI recommendation

6.2 Regular Monitoring

• We regularly audit our AI tools for accuracy, fairness, and compliance
• We monitor outcomes to identify any patterns that might indicate bias or unfairness
• We maintain logs of AI-assisted decisions for quality assurance purposes

6.3 Vendor Due Diligence

• We conduct due diligence on all AI tool providers to ensure their systems are designed and tested for fairness
• We require our vendors to provide transparency about how their systems work
• We do not use AI tools that cannot be adequately explained or monitored

7. Your Rights

Under the GDPR and the EU AI Act, you have the following rights in relation to AI-assisted recruitment:

7.1 Right Not to Be Subject to Solely Automated Decisions

You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. We uphold this right by ensuring human involvement in all decisions that affect your candidacy.

7.2 Right to Human Intervention

If you believe a decision affecting your application may have been influenced by an automated process, you have the right to request human review of the decision, express your point of view, and contest the decision.

7.3 Right to an Explanation

You have the right to request meaningful information about the logic involved in any automated processing that affects you. We will explain, in clear terms, what AI tools were used in processing your application, what factors the AI considered, and how the human recruiter reached their decision.

7.4 Right to Access

You have the right to request a copy of the personal data we hold about you, including any data processed by AI systems.

7.5 Right to Rectification

If any information about you is inaccurate, you have the right to have it corrected. This is particularly important if you believe that AI tools may have incorrectly parsed or interpreted information from your CV.

7.6 Right to Object

You have the right to object to certain types of processing. If you have concerns about how AI is being used in relation to your application, please contact us.

8. Fairness and Non-Discrimination

We are committed to ensuring that our use of AI does not result in unlawful discrimination. We take the following steps:

• Bias testing: We consider available supplier information on AI fairness and bias mitigation and ensure that recruiters review AI-assisted outputs before making recruitment decisions.
• Diverse training data: We select AI tools that have been trained on diverse and representative data sets.
• Regular audits: We conduct regular audits of AI-assisted outcomes to identify any discriminatory patterns as part of our BMS yearly audits.
• Human judgement: Human recruiters are trained to identify and counteract potential algorithmic bias.

If you believe you have experienced discrimination in our recruitment process, please contact us immediately using the details below.

9. Data Protection

All personal data processed through AI systems is handled in accordance with our Privacy Notice and the GDPR. Key principles include:

• Lawful basis: We process your data on the basis of legitimate interests, providing recruitment services, or, where applicable, your consent.
• Data minimisation: We only process data that is necessary for the recruitment purpose.
• Security: All AI systems we use employ appropriate technical and organisational security measures.
• Retention: Data processed by AI systems is retained in accordance with our data retention policy and deleted when no longer necessary.
• International transfers: Where AI tools involve transfers outside the EEA, appropriate safeguards are in place.

10. Transparency About Specific AI Tools

We currently use the following AI-assisted tools:

Tool/System	Purpose	Provider
JobAdder	CV parsing and database management	JobAdder Operations Pty Ltd.
Sales Nav	Identifying potential matches for roles	LinkedIn
LinkedIn Helper	Assists recruiters in identifying and importing publicly available professional profile information from LinkedIn for sourcing purposes. The tool is not used to score, rank, screen or automatically reject candidates.	LinkedIn Helper
Indeed Job Board	Advertising vacancies and receiving applications	Indeed
Copilot	Microsoft Copilot may be used for drafting, summarising and administrative support. It is not used as the sole basis for candidate screening, ranking, shortlisting, rejection or hiring decisions. Recruiters remain responsible for reviewing source information and applying professional judgement.	Microsoft

We do not use:

• AI-powered video interview analysis or emotion recognition
• Automated personality or psychometric assessments without human interpretation
• Social media scraping tools to assess cultural fit, analyse online activity, or filter candidates based on online presence. Recruitment sourcing tools may be used to collect publicly available professional profile and contact information only.
• Any AI system that makes autonomous hiring or rejection decisions

11. EU AI Act Compliance

The EU Artificial Intelligence Act classifies AI systems used in employment and recruitment as high-risk. As a deployer of such systems, we are committed to:

• Using AI systems only for their intended purposes
• Ensuring meaningful human oversight of all high-risk AI applications
• Maintaining logs of AI system use as required by law
• Suspending or ceasing use of any AI system that presents risks to candidates’ fundamental rights
• Cooperating with regulatory authorities and providing information when required

We keep our practices under continuous review to ensure ongoing compliance as the AI Act’s provisions come into full effect.

12. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or legal requirements. The "Last Reviewed" date at the top of this policy indicates when it was most recently updated.

13. Contact Us

If you have any questions about how we use AI in our recruitment processes, wish to exercise any of your rights, or have concerns about how your application has been handled, please contact:

Aileen Fitzgerald, Recruitment Manager, ICE Jobs
Phone: 091 475100
Email: jobs@icegroup.ie

You may also contact our Data Protection Officer at gdpr@icegroup.ie for data protection-related queries.

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
www.dataprotection.ie

14. Acknowledgement

This policy has been developed in accordance with guidance from the Employment and Recruitment Federation (ERF) and reflects our commitment to ethical, transparent, and legally compliant recruitment practices.