AI & Automated Decision Use Policy

Global Talent Pathway

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy governs the use of artificial intelligence (AI), machine learning, and other automated tools within Global Talent Pathway’s platforms and operations.

Its purpose is to:

  • ensure responsible, transparent, and lawful use of automation,

  • manage risks associated with automated processing,

  • prevent inappropriate reliance on automated outputs, and

  • align with government and enterprise expectations for algorithmic accountability.

2. Scope

This policy applies to:

  • all AI and automated systems used by Global Talent Pathway,

  • candidate-facing and employer-facing platform features,

  • internal operational and integrity controls,

  • third-party AI tools or services used on Global Talent Pathway’s behalf.

This policy applies across all jurisdictions in which Global Talent Pathway operates.

3. Policy Statement

Global Talent Pathway may use AI and automated tools to support its platforms and services.
Automation is used to assist decision-making, not to replace human accountability.

Global Talent Pathway takes reasonable, proportionate, and risk-based steps to ensure automated tools are used appropriately and do not cause unjustified harm.

4. Types of Automated Processing

AI and automated tools may be used for purposes including, but not limited to:

  • parsing and structuring application data,

  • identifying potential matches or suitability signals,

  • prioritising or ranking information for review,

  • detecting unusual, abusive, or fraudulent activity,

  • supporting operational efficiency and integrity controls.

Automated tools may generate signals, recommendations, or outputs, but do not make binding decisions on behalf of Global Talent Pathway.

5. Human Oversight and Accountability

Global Talent Pathway maintains human oversight over material decisions.

  • Automated outputs are reviewed, contextualised, or acted upon by humans where appropriate.

  • Employers and recruiters remain responsible for hiring and employment decisions.

  • Global Talent Pathway does not delegate legal or ethical responsibility to automated systems.

6. No Sole Reliance on Automation

Automated tools:

  • do not guarantee accuracy or completeness,

  • may produce false positives or false negatives,

  • must not be treated as determinative or conclusive.

Global Talent Pathway disclaims reliance on automated outputs as professional, legal, or employment advice.

7. Fairness and Bias Considerations

Global Talent Pathway takes reasonable steps to:

  • consider potential bias or unfair impact in automated processing,

  • avoid using protected characteristics as decision inputs where inappropriate,

  • monitor for unintended discriminatory effects where risks are identified.

This does not constitute a guarantee that automated systems are free from bias.

8. Transparency

Where automated processing materially affects users:

  • Global Talent Pathway provides high-level information about the use of automation through its Privacy Policy and platform notices,

  • users may raise questions or concerns through the Complaints & Disclosures Gateway.

Global Talent Pathway is not required to disclose proprietary algorithms or system details.

9. Data Protection and Security

AI and automated tools operate in accordance with:

  • the Privacy Policy,

  • the Information Security Policy,

  • the Records Management & Retention Policy.

Personal data used in automated processing must be:

  • relevant to the stated purpose,

  • protected by appropriate safeguards,

  • retained only as long as necessary.

10. Third-Party AI Tools

Where third-party AI services are used:

  • Global Talent Pathway undertakes reasonable due diligence,

  • contractual safeguards are applied where appropriate,

  • use is subject to this policy and related controls.

Global Talent Pathway does not guarantee the behaviour or performance of third-party AI systems beyond its reasonable control.

11. Incident Management

Concerns relating to:

  • automated decision use,

  • suspected unfair outcomes,

  • misuse or malfunction of AI tools,

must be reported through the Complaints & Disclosures Gateway.

Issues are assessed in accordance with the Risk Management Framework.

12. Governance and Review

Use of AI and automation is:

  • subject to internal governance oversight,

  • reviewed periodically for risk and appropriateness,

  • adjusted where material risks are identified.

Material changes to automated processing are assessed prior to deployment.

13. Relationship to Other Policies

This policy operates alongside:

  • Privacy Policy,

  • Information Security Policy,

  • Records Management & Retention Policy,

  • Risk Management Framework,

  • Complaints & Disclosures Gateway,

  • Terms of Use.

In the event of inconsistency, Tier 1 policies prevail.

14. Review

This policy will be reviewed annually or earlier if:

  • regulatory expectations change,

  • platform functionality materially changes,

  • significant issues arise.