XXpressApply

Legal · XA-LEGAL-AIT

AI Transparency Notice

Entity
XpressApply Ltd, Republic of Cyprus
Reg. No.
HE 000000
Effective
1 June 2026
Status
Version 1.0 · Draft for review

This AI Transparency Notice explains how XpressApply Ltd uses automated processing to assess candidates within the XpressApply service (the "Service"), the safeguards we apply, and the rights available to you before, during and after an automated assessment. It supplements, and should be read together with, our Privacy Notice.

It is provided in furtherance of the transparency obligations under Articles 13 to 15 and 22 of the GDPR and the transparency and human-oversight controls that apply to high-risk AI systems used in recruitment.

1.When you see this notice

  1. 1.1We link to this Notice before candidate signup, before application consent, during the interview readiness and consent step, from automated decline and human-review surfaces, and from assistant experiences that explain scores or matches.
  2. 1.2You do not need to accept an automated assessment without being able to read this Notice first.

2.What the automated assessment does

  1. 2.1The Service may parse your CV or profile, screen your evidence against a role's requirements, conduct or transcribe a structured interview, evaluate your answers against a role-family rubric, produce a scorecard, and re-score the same evidence against other roles where you have consented to sharing.
  2. 2.2The scorecard may be generated before a human listens to your interview, and therefore constitutes automated processing. We treat the result as decision support rather than a final hiring decision.
  3. 2.3Employers remain responsible for hiring decisions. XpressApply does not authorise silent automated declines unless the candidate-facing decline and human-review surface is available.

3.Legal basis

  1. 3.1We carry out this processing to perform our agreement with you to provide the Service and, in respect of voice recordings and any special category data, on the basis of your explicit consent under Article 9(2)(a) GDPR.
  2. 3.2You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

4.How we keep the assessment fair

  1. 4.1Every candidate assessed for a role family answers against the same rubric, and the interview is recorded so that the assessment can be reviewed as evidence.
  2. 4.2We assess job-relevant language on the CEFR scale and do not penalise your accent.
  3. 4.3We do not make an assessment on the basis of curriculum-vitae keywords alone, and the same interview may be re-scored against multiple roles so that a single conversation can count towards many opportunities.
  4. 4.4Protected attributes and proxy features are excluded from scoring and matching features. Where fairness measurement is performed, it is separated from the hiring score and handled under the applicable consent, legal and audit controls.
  5. 4.5Each AI assessment is designed to keep an audit trail of the model version, rubric version, inputs, scores and reasoning so that a review can be grounded in the same evidence.

5.Human oversight and your rights

  1. 5.1You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects concerning you (Article 22 GDPR).
  2. 5.2You may request human intervention, express your point of view, and contest any automated outcome. Where a human review changes the outcome, the revised result replaces the automated one in your record.
  3. 5.3If you receive an automated decline, the decline surface explains the evidence considered and provides a way to request human review. You may also contact us using the details below.
  4. 5.4You may access, export or delete your data, withdraw consent where applicable, and exercise your other rights as described in our Privacy Notice.

6.Data used and retention

  1. 6.1The assessment may use your CV or profile, application record, role requirements, role rubric, interview recording, transcript, scorecard, matching evidence, consent records and audit logs.
  2. 6.2The assessment does not use payment data, unrelated employer data, or protected attributes as scoring inputs. CV parsing, screening, voice interview scoring, assessment re-scoring and matching are covered by the XpressApply DPIA and audit-log controls before beta release.
  3. 6.3Recordings, transcripts and scorecards are retained on a defined retention schedule so that an assessment can be checked if you request a review, after which they are deleted or anonymised. You may request erasure sooner, subject to any retention required by law.

7.Assistant explanations

  1. 7.1When the candidate or employer assistant explains a match, score or shortlist, it is expected to use consented and audited evidence rather than inventing reasons.
  2. 7.2Assistant explanations are informational. They do not replace the official scorecard, employer decision, human-review outcome or legal notices.

8.Limitations

  1. 8.1Automated assessment is a tool to support fair and consistent evaluation; it does not guarantee any particular outcome, and hiring decisions remain the responsibility of the relevant employer.

9.Contact

  1. 9.1If you have questions about how the automated assessment works or wish to exercise your rights, contact us at privacy@xpressapply.com or our Data Protection Officer at dpo@xpressapply.com.

This document is a draft template prepared for the XpressApply prototype and is provided for information only. It does not constitute legal advice and should be reviewed and adapted by qualified legal counsel before any production use.

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