Input data and information sources
Candidates write their own CVs and cover letters. Every application contains a name, contact details, career history and often a photograph.
Also known as: AI-based candidate screening
The system uses CVs and cover letters to identify the best match for a role and suggest whom the company should invite for interview.
Understand the use case
Controversial cases have attracted particular attention: Amazon abandoned a system in 2018 because it disadvantaged women, and Workday faces litigation in the US.
This page describes a typical system design. Actual data flows and permissions depend on your implementation.
System design and data flows
CVs, cover letters and certificates arrive through the application portal, alongside the role's requirements.
Candidates write their own CVs and cover letters. Systems that also analyse video interviews or photographs add image and audio to text.
The system extracts information and compares education, experience and skills with the requirements.
The model processes application documents and compares identified characteristics with defined requirements. This produces classifications or a ranking for shortlisting. The ranking reflects the chosen assessment method and is not a comprehensive statement about a person's suitability.
Each application receives a score, ranking or summary.
The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.
HR uses this output to decide whom to invite and whom to reject.
Integration determines whether the result is simply displayed, adopted after approval or written directly into a business application. These variants differ in their data flows and permissions.
Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.
7 review first20 clarify6 baseline threats
The diagram shows the typical architecture. Select a component to see what happens there and adapt its features to your system. Enable “Analysis guidance” to see which threats need reviewing for this architecture. The page's checklist continues to describe the typical case.
None yet. Each change will appear here.
In this system design: 7 to review first, 20 to clarify, 6 baseline threats.
External access: Depends on your system
To clarify
Input: Part of every AI system
Review first
To clarify
Third-party content: Present
AI model: Part of every AI system
To clarify
Baseline for every AI system
Provider service: Present
Review first
To clarify
Document collection: Depends on your system
To clarify
Training and feedback: Depends on your system
To clarify
Result: Part of every AI system
Review first
To clarify
Business application or equipment: Depends on your system
To clarify
person: Part of every AI system
Review first
Affected person: Present
Unapproved AI services: Depends on your system
To clarify
Supply chain and technical foundations: 5 baseline threats applying to every AI system
Baseline for every AI system
Assigns tasks to workers and evaluates their performance
Personalised online advertising (behavioural targeting)
Targets job advertisements at selected people
Candidates write their own CVs and cover letters. Every application contains a name, contact details, career history and often a photograph.
Assessment is usually part of applicant tracking software, with a model supplied by the vendor.
Some systems search past applications for suitable candidates. Some companies train the model on their past hiring decisions, as Amazon did.
Depending on the company, the system sends rejections itself or only suggests a ranking. If applicant tracking software runs in the cloud, applications leave the company.
Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.
Assess risks and determine measures
Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.
Relate review candidates to actual data flows: what could happen, and who would be affected?
Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.
Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.
A total of 33 threats from the threat catalogue may be relevant to this use case.
Also review: whether the system disadvantages groups
Check whether selection, ranking or assessment disadvantages people with protected characteristics, such as sex, age or origin.
Candidates can repeat job advertisement keywords or hide them in their CVs. The system then ranks an application more highly than the candidate's qualifications justify.
Recruiters often look only at the top-ranked candidates. Those placed lower have little chance, even when the ranking is wrong.
The ranking passes into the applicant tracking system and can trigger rejections. A scoring error thus becomes a direct decision about a person.
Training data or an adopted base model can introduce hidden triggers for misbehaviour.
Listed because of this characteristic
Targeted queries can recover some personal or protected training data from the model.
Listed because of these characteristics
Sensitive Information Disclosure
Confidential content can appear in answers, supplied context or logs.
Listed because of these characteristics
Exfiltration from ML Application
Protected data can leak through tools, network connections, storage or insiders.
Listed because of this characteristic
Up to 20 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. Three of these are particularly important here and are therefore listed above.
Each Yes adds further threats to your checklist, up to 20 in total. If you cannot yet answer a question, include its threats in your review.
How your system is built
How you operate the system
Newer systems use a language model to summarise applications; traditional approaches only produce a ranking.
If yes, add
A language model follows instructions, including ones someone has invisibly embedded in a CV.
If yes, add
Some systems search past applications for suitable candidates.
If yes, add
Some systems map skills and occupations using a database of concepts and their relationships.
If yes, add
Depending on the company, the system sends rejections itself or only suggests a ranking.
If yes, add
Recruitment agencies often hold applications for several client companies in the same repository.
If yes, add
Some companies train the model on their past hiring decisions, as Amazon did.
If yes, add
A model trained on past hires adopts their patterns, including discriminatory ones.
If yes, add
HR decisions can feed back as new training examples.
If yes, add
Systems that also analyse video interviews or photographs add image and audio to text.
If yes, add
If yes, add
These questions arise for almost every AI system.
If yes, add
If yes, add
If yes, add
If yes, add
Anyone can submit documents through an application portal for the system to evaluate.
If yes, add
Staff who upload applications to a freely available chat service for comparison do so without approval.
If yes, add
Measures for the priority review areas are expanded. Each linked measure explains how to implement it.
Controls for the remaining threats are available on their pages in the threat catalogue.
For every AI system Applies since 2 February 2025.
Depending on use Review trigger since 2 February 2025.
Depending on use Review trigger since 2 August 2025.
In typical use Review trigger from 2 December 2027.
Applies if staff or appointed representatives operate or use AI systems.
Applies since 2 February 2025.
Detailed obligations
Applies if the system screens or filters applications or evaluates candidates, even when a person ultimately decides whom to invite.
Applies from 2 December 2027.
Detailed obligations
Applies if the system infers candidates' emotions or intentions from their faces or voices in video interviews.
Applies since 2 February 2025.
Detailed obligations
Applies if a large language model or another third-party general-purpose model analyses or summarises applications.
Applies since 2 August 2025.
Detailed obligations
Article 22 GDPR
If a rejection is based solely on automated assessment, the prohibition on automated individual decisions applies, subject to its exceptions.
Sections 1, 7 and 22 of Germany's General Act on Equal Treatment (AGG)
The Act prohibits disadvantaging applicants on grounds such as sex, age, disability or ethnic origin. Where evidence suggests discrimination, the employer must prove otherwise.
Open the legislation Sections 1, 7 and 22 of Germany's General Act on Equal Treatment (AGG)
Classify your system with the quick checker All obligations in the obligations compass
Review these threats for every AI system, whatever its purpose.
If any of these features does apply to your system, add the listed threats.
Does the system generate or edit images, sounds, voices or videos?
If yes, add
Does the system create new content from open-ended requests that people read, see or hear directly? Translation, reading aloud and transcription do not count.
The system evaluates submitted documents and does not create new content for external audiences.
If yes, add
Does the system formulate answers from retrieved documents?
If yes, add
Does the system remember content from earlier conversations or tasks and reuse it later?
If yes, add
Does the system call other programs, interfaces or search services itself, even if only to read?
If yes, add
Does the system determine its next steps itself based on earlier results?
If yes, add
Does the system delegate tasks to other AI agents or incorporate their results?
If yes, add
Is the system connected to tools or data sources through the Model Context Protocol (MCP)?
If yes, add
Does the system generate code, scripts or database queries for further use?
If yes, add
Does the system execute programs, scripts or commands itself?
If yes, add
EU AI Act, Annex III, point 4(a)
The Act expressly lists AI systems that screen or filter applications or evaluate candidates in Annex III.
AI Incident Database, Incident 37 (Amazon)
The database documents Amazon's scoring system, which gave women's applications lower scores.
Holland & Knight on Mobley v. Workday, May 2025
The law firm reports litigation concerning AI-based candidate assessment in real-world use.
Federal Network Agency, AI in businesses, July 2025 report
The report states that 24 per cent of AI-using companies use it in human resources overall.
Digital Labour Society think tank (BMAS), Policy brief on artificial intelligence in recruitment
The Federal Labour Ministry's think tank describes AI systems screening CVs as part of recruitment.
Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured