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Can we use AI in HR processes (recruitment, performance)?

You can, but recruitment and performance are among the most exposed uses there are. The AI Act places systems used in hiring, promotion and performance evaluation in the high-risk class, wh…

Updated · July 20261 min readCategory · Legal Tech
Short answer

You can, but recruitment and performance are among the most exposed uses there are. The AI Act places systems used in hiring, promotion and performance evaluation in the high-risk class, which brings obligations of transparency, record-keeping and human oversight. In Türkiye the same process runs into the Personal Data Protection Law (No. 6698): candidates…

You can, but recruitment and performance are among the most exposed uses there are. The AI Act places systems used in hiring, promotion and performance evaluation in the high-risk class, which brings obligations of transparency, record-keeping and human oversight. In Türkiye the same process runs into the Personal Data Protection Law (No. 6698): candidates have to be given an information notice, and the law gives a data subject rights against a decision produced by automated processing, including the right to object to it.

There is a third layer that is easy to miss. The equal-treatment principle in the Labour Law (No. 4857) means the model itself has to be tested for discriminatory outcomes — a system that quietly filters out a protected group is a breach whatever its accuracy figures say. The defensible design is consistent: let the tool support a human decision rather than take it, document the reasoning behind each decision, keep the records the AI Act expects, and give candidates a route to object that a person actually reviews.

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