EU AI Act Compliance
Last updated:Applies globally · Primary market: European Union
Wigiwork uses automated systems ("Wigi IQ Labs™") to support anonymous discovery, shortlisting, and recommendations. Because these systems are used in a recruitment context, Wigiwork treats them as high-risk AI systems under the EU AI Act (Regulation (EU) 2024/1689) and applies the governance, transparency, and oversight measures described below. This statement forms part of the Wigiwork Terms of Service, AI & Automated Decision Notice, AI Bias & Fairness, and Data Protection Notice.
1. Purpose & Scope
This statement explains how Wigiwork approaches its obligations under the EU AI Act for AI systems used in employment and recruitment. It covers the automated systems that influence which anonymous candidates are surfaced to employers and is a summary for users; it does not replace the full technical documentation Wigiwork maintains internally.
2. Why Our Systems Are High-Risk
The EU AI Act classifies AI systems used for the recruitment or selection of candidates — including to filter applications, evaluate candidates, or rank them — as high-risk (Annex III, point 4(a)). Wigiwork's matching, ranking, and shortlisting features fall within this category, so we apply high-risk obligations even where our role is to support, not make, hiring decisions.
3. Our Role Under the Act
Wigiwork acts as a provider of the automated systems it builds and operates. Employers who use the Services to recruit are deployers and have their own obligations under the Act, including human oversight, worker information, and lawful use. This statement addresses Wigiwork's provider responsibilities; it does not discharge employers' deployer obligations.
4. How We Meet High-Risk Obligations
Wigiwork applies measures aligned to the Act's requirements for high-risk systems:
- Risk management — ongoing identification and mitigation of risks across the system lifecycle
- Data governance — use of relevant, representative professional data, with identity and protected attributes excluded from ranking signals
- Technical documentation — maintained records describing system purpose, design, and performance
- Logging & traceability — automatic logging of relevant events to support auditability
- Transparency — clear information to users about how automated systems are used, in this statement and the AI & Automated Decision Notice
- Human oversight — systems are designed so that final hiring decisions rest with humans, never the AI
- Accuracy, robustness & security — testing and safeguards appropriate to the system's purpose
5. Transparency to Candidates & Employers
Wigiwork informs users that automated systems are used in discovery, shortlisting, and ranking. Candidates and employers are told that these outputs are recommendations only, are probabilistic, and may be incomplete or inaccurate, as set out in our AI & Automated Decision Notice.
Wigiwork does not use personal identity or protected demographic characteristics to determine relevance or ranking. Transparency under this statement means clear, plain-language information about the categories of factors and signals used by our systems; it does not extend to disclosure of Wigiwork's proprietary source code, model architecture, weighting formulas, or other trade secrets, which remain confidential and are protected accordingly.
6. Human Oversight
Wigiwork's automated systems do not approve, reject, or hire candidates. Shortlists and rankings are recommendations that support human evaluation, and employers remain solely responsible for all recruitment decisions. Where automated processing produces legal or similarly significant effects, individuals may exercise rights to information, human review, and to contest the outcome as described in our AI & Automated Decision Notice.
7. Bias & Fairness Testing
Wigiwork tests its matching, ranking, and shortlisting systems for bias and fairness before material changes are deployed and at least annually. Details of what we test and how are set out in our AI Bias & Fairness, which supports this statement.
8. Prohibited Practices
Wigiwork does not use its AI systems for practices prohibited by the EU AI Act. In particular, our systems do not perform social scoring, do not infer emotions in the workplace, and do not use biometric categorisation to deduce protected characteristics. Uploaded photos used for WigiPic avatars are processed once and deleted, with no facial recognition or biometric identification, as described in our Data Protection Notice.
9. Data Protection Alignment
Processing of personal data by these systems is governed by our Privacy Policy and Data Protection Notice, including the lawful bases relied on and the rights available to individuals. The AI Act measures described here operate alongside, and do not replace, our GDPR and UK GDPR obligations.
10. Continuous Compliance
Compliance with the EU AI Act is an ongoing program. Wigiwork monitors regulatory guidance and applicable transition timelines, updates its documentation and controls as obligations take effect, and revises this statement to reflect material changes. The "Last updated" date above reflects the most recent revision.
11. Limitations
This statement describes Wigiwork's approach and commitments; it is not a certification or a guarantee of any specific regulatory outcome. AI systems are probabilistic and imperfect, and obligations under the Act continue to develop through implementing guidance and standards.
12. Contact
For questions about this summary or our fairness testing:
Wigiwork Inc. PBC
Postal: 2261 Market St, San Francisco, CA 94114-1612, USA, Attn: Legal
Email: legal@wigiwork.com (general) · privacy@wigiwork.com (data rights)
13. EU Authorised Representative
Pursuant to Article 22 of the EU AI Act (Regulation (EU) 2024/1689), Wigiwork Inc. PBC, as a provider established outside the Union of a high-risk AI system falling within Annex III, point 4(a), has designated an authorised representative in the European Union by written mandate. Inquiries from European supervisory authorities or data subjects regarding our algorithmic shortlisting systems, compliance documentation, or related data processing may be directed to:
Prighter EU Rep GmbH
Schellinggasse 3/10, 1010 Vienna, Austria
Compliance portal: Prighter