AI Act Compliance (EU)

This statement explains Wigiwork's high-level approach to the EU AI Act where that law applies to Wigiwork, a relevant AI system, or a particular use of Wigiwork's services.

It covers relevant automated systems that may support:

• professional discovery and candidate-job matching;
• professional sourcing, outreach matching, and job-requirements checks;
• ranking, recommendations, and shortlist views;
• profile structuring, Wigi Highlights, automated profile explanations, and other candidate-related outputs;
• verification, moderation, safety, and fraud prevention; and
• other recruitment-related or platform functions.

The requirements applicable to a system may depend on its intended purpose, classification, configuration, deployment context, Wigiwork's legal role, the activities of employers or other users, and the applicable implementation timeline.

This statement is a public legal summary. It does not replace system-specific instructions, contractual obligations, privacy notices, employer compliance duties, or applicable law.

Wigiwork assesses each relevant AI system according to its:

• intended purpose and supported functions;
• design, configuration, and deployment context;
• actual or reasonably foreseeable use;
• effect on candidates, employers, and hiring workflows;
• Wigiwork's applicable legal role; and
• applicable EU AI Act requirements and implementation dates.

Recruitment-related AI systems used for sourcing, targeted job invitations, matching, filtering, ranking, or evaluating candidates may fall within Annex III, point 4(a), of the EU AI Act. Classification is assessed under Article 6, including its rule that Annex III systems that profile natural persons are high-risk. Wigiwork applies the requirements relevant to the classification, its legal role, and applicable implementation dates.

Not every automated feature has the same intended purpose or legal classification. Features with different intended purposes, including general assistance, profile presentation, platform operation, safety, fraud prevention, or other functions, may be subject to different obligations.

The inclusion of a feature in this public statement does not by itself establish that every configuration or use of that feature is high-risk or subject to identical requirements.

Wigiwork reassesses a system where required by applicable law following material changes to its intended purpose, functionality, deployment context, actual use, legal role, or applicable regulatory requirements.

The legal role of Wigiwork or another party under the EU AI Act may vary according to the relevant system, intended purpose, contractual structure, configuration, deployment context, and actual use.

Depending on the circumstances, relevant parties may include:

• Wigiwork as a provider or another regulated operator;
• an employer, recruiter, agency, or other organization as a deployer;
• an authorized representative, importer, distributor, service provider, or other party where applicable; and
• individuals affected by the use or output of the system.

Each party remains responsible for the obligations applying to its own role and activities.

Employers, recruiters, agencies, and other deployers remain responsible for:

• using Wigiwork systems only for their intended and authorized purposes;
• following applicable instructions and human-oversight requirements;
• providing notices or information required for their use;
• monitoring their use and addressing relevant risks or incidents; and
• complying with applicable recruitment, employment, equality, privacy, transparency, and AI-law obligations.

Nothing in this statement assigns one legal classification to Wigiwork or another party across every system or use case, transfers a user's legal responsibilities to Wigiwork, or limits Wigiwork's own obligations under applicable law.

Where required by the EU AI Act, Wigiwork develops and maintains governance and compliance measures appropriate to the relevant system, intended purpose, deployment context, risks, and Wigiwork's legal role.

Depending on the applicable requirements, these measures may address:

• risk management throughout the system lifecycle;
• data quality and data-governance practices;
• technical documentation and recordkeeping;
• transparency and information for deployers and affected individuals;
• human oversight;
• accuracy, robustness, and cybersecurity;
• testing, monitoring, incident handling, and corrective action;
• quality-management and accountability responsibilities; and
• conformity assessment, registration, or regulatory cooperation where applicable.

The measures applicable to one system may differ from those applicable to another system or use case.

Wigiwork protects confidential documentation, internal control evidence, trade secrets, and security-sensitive implementation information to the extent permitted by applicable law. This does not limit information, explanations, or access required by law, including disclosure to competent authorities.

Nothing in this section represents that every Wigiwork automated feature has the same classification or is subject to every measure listed above.

Wigiwork provides high-level information about relevant AI and automated systems through this statement, related legal notices, and point-of-use explanations where required or appropriate.

Depending on the system, Wigiwork's legal role, and applicable requirements, information may address:

• the system's intended purpose and supported functions;
• the types of automated outputs it may produce;
• relevant capabilities, limitations, and foreseeable risks;
• the need for independent review and human oversight;
• appropriate use and prohibited or unauthorized uses; and
• applicable rights, contact routes, or review procedures.

Automated outputs may include recommendations, rankings, Wigi Highlights, automated profile explanations, shortlist views, or other information intended to support human evaluation. They may be incomplete, inaccurate, outdated, misleading, or unsuitable for a particular purpose.

Wigiwork does not intentionally use protected characteristics as ranking, matching, recommendation, shortlist, or visibility factors. Wigiwork-controlled direct identity fields are not intentionally used to assess professional suitability or rank candidates. Relevant company identifiers may be used to apply Hide From, employer-conflict protections, and other privacy or access restrictions.

Where applicable law requires additional information or explanations for deployers, users, or affected individuals, Wigiwork will provide the required information in an understandable form. Proprietary, confidential, and security-sensitive information is protected to the extent permitted by law.

Employers, recruiters, agencies, and other deployers remain responsible for providing any notices, instructions, or disclosures required for their own use of Wigiwork systems.

Wigiwork's automated systems may support Discovery, matching, ranking, recommendations, Wigi Highlights, automated profile explanations, shortlist views, verification, moderation, safety, and fraud-prevention functions.

Employers make final hiring and employment decisions. Wigiwork's automated sourcing, matching, and requirements checks can affect which professionals are invited, which jobs or profiles are presented, and whether an initial job-specific outreach share proceeds. Wigiwork remains responsible for the obligations applying to its own processing.

Where required by the EU AI Act or other applicable law, Wigiwork applies or supports human-oversight measures appropriate to the relevant system, use, risk, and Wigiwork's legal role. These measures may include:

• providing information about the system's intended purpose and limitations;
• enabling relevant outputs to be reviewed and interpreted by an appropriate person;
• supporting correction, restriction, disregard, or escalation of an output where appropriate;
• helping reduce over-reliance on automated outputs; and
• monitoring for errors, unexpected behavior, misuse, or material risks.

Employers, recruiters, agencies, and other deployers remain responsible for independently reviewing automated outputs, ensuring that personnel using them have appropriate authority and understanding, and complying with applicable human-oversight and employment-law obligations.

Automated outputs must not be treated as verified facts, final decisions, or guaranteed assessments of eligibility, qualifications, professional ability, suitability, or entitlement to an employment outcome.

Where applicable law provides individual rights concerning automated processing, information, human review, objection, correction, or contestation may be available as described in the AI & Automated Decision Notice and Data Protection Notice.

Wigiwork reviews relevant automated systems for fairness, performance, and potential bias using measures appropriate to the system's intended purpose, deployment context, stage of deployment, Wigiwork's applicable legal role, and applicable requirements.

Where legally permitted, technically feasible, and supported by appropriate information, relevant measures may consider:

• unfair or unjustified differences in automated outputs;
• data quality, representativeness, and potential proxy effects;
• accuracy, consistency, robustness, and known limitations;
• the effectiveness of human oversight and user instructions; and
• appropriate monitoring, correction, or risk-reduction measures.

Wigiwork does not intentionally use protected characteristics or Wigiwork-controlled direct identity fields as ranking, matching, recommendation, shortlist, or visibility factors.

The identity and protected-characteristic limits described in §5 apply to this processing.

No fairness review, testing process, or governance measure guarantees that every bias, error, proxy effect, or discriminatory misuse will be prevented.

Additional information is provided in AI Bias & Fairness.

Wigiwork does not intend or authorize its AI systems to be used for conduct prohibited by the EU AI Act or other applicable law.

Users must not use Wigiwork or its automated systems for:

• unlawful discrimination or prohibited profiling;
• prohibited social scoring;
• prohibited workplace emotion recognition or inference;
• biometric categorization intended to infer sensitive or protected characteristics;
• unauthorized facial recognition, biometric identification, or identity matching;
• manipulative, deceptive, exploitative, or coercive practices prohibited by applicable law; or
• another prohibited AI practice.

Users must not configure, combine, prompt, manipulate, or use Wigiwork outputs or information to create a prohibited use outside the platform.

Photos uploaded to generate WigiPics are processed only for the avatar-generation purpose described in Wigiwork's applicable privacy and WigiPic notices. Wigiwork does not use those source photos for facial recognition, biometric identification, or demographic inference.

Wigiwork may restrict or prohibit a use, configuration, integration, or workflow where reasonably necessary to prevent unlawful or prohibited AI practices.

Personal data processed through Wigiwork's AI and automated systems remains subject to the Privacy Policy, Data Protection Notice, and applicable privacy and data-protection law.

Where applicable, Wigiwork applies relevant data-protection principles and safeguards concerning:

• lawful and transparent processing;
• purpose limitation and data minimization;
• accuracy and correction;
• confidentiality and security;
• retention and deletion; and
• individual rights concerning personal data and automated processing.

Compliance with the EU AI Act operates alongside, and does not replace, obligations arising under the GDPR, UK GDPR, or other applicable privacy and data-protection laws.

Individuals, including non-members, may exercise applicable access, correction, objection, restriction, human-review, or other rights through the procedures described in the AI & Automated Decision Notice, Privacy Policy, and Data Protection Notice.

You may request human review of an inaccurate matching result through support@wigiwork.com. Applicable privacy and automated-processing rights requests may be submitted to privacy@wigiwork.com without registering.

Wigiwork monitors relevant automated systems and reassesses applicable EU AI Act obligations where appropriate, including when there are material changes to:

• a system's intended purpose, functionality, or configuration;
• deployment context or use;
• Wigiwork's applicable legal role;
• identified risks or incidents; or
• applicable legal or regulatory requirements.

Wigiwork may update its governance, documentation, safeguards, transparency information, and this public statement to reflect relevant changes.

The "Last Updated" date identifies the most recent revision of this statement.

This statement is a high-level public summary of Wigiwork's approach to the EU AI Act. It is not:

• a certification of compliance;
• a guarantee of a particular system classification or regulatory outcome;
• legal advice to employers, recruiters, agencies, or other users; or
• a representation that identical obligations apply to every system, configuration, deployment, or use case.

The legal classification and obligations applicable to an automated system may depend on its intended purpose, functionality, deployment context, Wigiwork's legal role, the user's activities, and applicable implementation dates or regulatory guidance.

AI-generated and automated outputs may contain errors, omissions, inaccuracies, or unexpected results and must be independently reviewed before reliance.

Employers, recruiters, agencies, and other users remain responsible for assessing and complying with the EU AI Act and other laws applicable to their own use of Wigiwork.

For questions about this statement, automated-processing rights, or related privacy matters:

Legal: legal@wigiwork.com
Privacy: privacy@wigiwork.com

Where the EU AI Act requires Wigiwork to appoint an authorised representative, Wigiwork will maintain the required appointment and provide the applicable representative information through the Regulatory Representatives page.

The identity, role, territorial scope, and effective status of any representative are governed by the information published on that page and applicable law.