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ICO Recommendations for AI Tools in Recruitment

At Sapia.ai, we’re dedicated to creating a hiring experience that is transparent, inclusive, and respectful of every candidate’s privacy. This month, the UK Information Commissioner’s Office (ICO)—the UK’s independent authority on upholding information rights and promoting data privacy— released new recommendations for AI developers and providers of recruitment tools, focused on protecting jobseekers’ rights and privacy. We’re proud to have contributed to the ICO’s audit and review of industry practices and to have implemented all recommendations specific to our platform.

The ICO conducted consensual audits with several organisations across various AI use cases. Throughout the process, the ICO was keen to understand how Sapia.ai and other providers process personal data, aiming to provide practical guidance for improving data protection and addressing information rights challenges in recruitment AI.

In total, these audits led to nearly 300 recommendations aimed at improving compliance across the industry. The recommendations included a range of practices to ensure fairness and transparency in processing candidates’ data. Key areas of focus included processing personal information fairly, minimising data collection, clearly explaining data processing activities, avoiding unlawful data repurposing, and conducting thorough risk assessments to evaluate privacy impacts — principles that align closely with our core values.

Since these recommendations spanned various AI applications, Sapia.ai received a small subset relevant specifically to our platform, and we’re proud to have fully integrated the ICO’s feedback into our approach.

Our Commitment to Continuous Improvement

As part of our engagement with the ICO, we reviewed and refined our practices. For instance, in late 2023, we ended the practice of inferring special category data from candidate names when this information wasn’t directly provided. This adjustment underscores our dedication to handling personal data transparently and responsibly.

The ICO’s audit also highlighted several existing practices at Sapia.ai that support our commitment to transparency, fairness, and data security. Our FAIR™ Framework received special recognition for promoting fairness in AI recruitment by offering clear guidance on reducing bias and fostering trust in AI-driven hiring. This framework is central to our efforts to create an equitable and transparent hiring experience—one where every candidate feels valued and seen.

Upholding Robust Security Standards

Beyond privacy, security is fundamental to our operations. The ICO acknowledged our strong commitment to information security, highlighting our programme of annual external assessments for compliance with ISO27001, ISO27017/18, and SOC2 Type 2 certifications. These certifications reflect our rigorous standards for data security, ensuring that our systems and processes protect personal data effectively. By undergoing these assessments, we assure our clients that our security practices are not only robust but also regularly reviewed to meet evolving standards in data protection.

Supporting Clients with Training and Resources

We believe that compliance and fairness extend beyond our technology to include the way clients understand and use our platform. That’s why, as part of our onboarding process, we provide comprehensive system training for new clients. This includes guidance on interpreting assessments and navigating the management information dashboard, helping clients use our system as it was designed. We also support clients in completing their own Data Protection Impact Assessments (DPIAs), empowering them to evaluate and address privacy risks in line with best practices.

Further, we provide accessible reference guides, or product ‘explainers’. These resources clarify the mechanics of our system and the security measures we have in place to protect personal data, enhancing client confidence and trust in our technology.

Building a Fairer Hiring Experience

We’re grateful for the opportunity to collaborate with the ICO and are inspired by their recognition of AI’s potential to make a positive impact on society. At Sapia.ai, we’ll continue to prioritise fairness, security, and privacy, working to create a hiring experience where every candidate feels valued and understood.

Our commitment to continuous improvement means we actively monitor changes in the privacy landscape and adapt to new developments. As AI legislation evolves and privacy standards are refined, we strive to proactively implement any required changes—ensuring our technology not meets and anticipates future standards.


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Mirrored diversity: why retail teams should look like their customers

Walk into any store this festive season and you’ll see it instantly. The lights, the displays, the products are all crafted to draw people in. Retailers spend millions on campaigns to bring customers through the door. 

But the real moment of truth isn’t the emotional TV ad, or the shimmering window display. It’s the human standing behind the counter. That person is the brand.


The missing link in retail hiring

Most retailers know this, yet their hiring processes tell a different story. Candidates are often screened by rigid CV reviews or psychometric tests that force them into boxes. Neurodiverse candidates, career changers, and people from different cultural or educational backgrounds are often the ones who fall through the cracks.

And yet, these are the very people who may best understand your customers. If your store colleagues don’t reflect the diversity of the communities you serve, you create distance where there should be connection. You lose loyalty. You lose growth.

We call this gap the diversity mirror.


What mirrored diversity looks like

When retailers achieve mirrored diversity, their teams look like their customers:

  • A grocery store team that reflects the cultural mix of its neighbourhood.
  • A fashion store with colleagues who understand both style and accessibility.
  • A beauty retailer whose teams reflect every skin tone, gender, and background that walks through the door.

Customers buy where they feel seen – making this a commercial imperative. 

 

How to recruit seasonal employees with mirrored diversity

The challenge for HR leaders is that most hiring systems are biased by design. CVs privilege pedigree over potential. Multiple-choice tests reduce people to stereotypes. And rushed festive hiring campaigns only compound the problem.

That’s where Sapia.ai changes the equation: Every candidate is interviewed automatically, fairly, and in their own words.

  • Bias is measured and monitored using Sapia.ai’s FAIR™ framework.
  • Outcomes are validated at scale: 7+ million candidates, 52 countries, average candidate satisfaction 9.2/10.
  • Diversity can be measured: with the Diversity Dashboard, you can track DEI capture rates, candidate engagement, and diversity hiring outcomes across every stage of the funnel.

With the right HR hiring tools, mirrored diversity becomes a data point you can track, prove, and deliver on. It’s no longer just a slogan.

 

Retail recruiting strategies in action: the David Jones example

David Jones, Australia’s premium department store, put this into practice:

  • 40,000 festive applicants screened automatically
  • 80% of final hires recommended by Sapia.ai
  • Recruiters freed up 4,000 hours in screening time
  • Candidate experience rated 9.1/10

The result? Store teams that belong with the brand and reflect the customers they serve.

Read the David Jones Case Study here 👇


Recruiting ideas for retail leaders this festive season

As you prepare for festive hiring in the UK and Europe, ask yourself:

  • How much will you spend on marketing this Christmas?
  • And how much will you invest in ensuring the colleagues who deliver that brand promise reflect the people you want in your stores?

Because when your colleagues mirror your customers, you achieve growth, and by design, you’ll achieve inclusion.

See how Sapia.ai can help you achieve mirrored diversity this festive season. Book a demo with our team here. 

FAQs on retail recruitment and mirrored diversity

What is mirrored diversity in retail?

Mirrored diversity means that store teams reflect the diversity of their customer base, helping create stronger connections and loyalty.

Why is diversity important in seasonal retail hiring?

Seasonal employees often provide the first impression of a brand. Inclusive teams make customers feel seen, improving both experience and sales.

How can retailers improve their hiring strategies?

Adopting tools like AI structured interviews, bias monitoring, and data dashboards helps retailers hire fairly, reduce screening time, and build more diverse teams.

 

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The Diversity Dashboard: Proving your DEI strategy is working

Why measuring diversity matters

Organisations invest heavily in their employer brand, career sites, and EVP campaigns, especially to attract underrepresented talent. But without the right data, it’s impossible to know if that investment is paying off.

Representation often varies across functions, locations, and stages of the hiring process. Blind spots allow bias to creep in, meaning underrepresented groups may drop out long before offer.

Collecting demographic data is only step one. Turning it into insight you can act on is where real change and better hiring outcomes happen.

What is the Diversity Dashboard?

The Diversity Dashboard in Discover Insights, Sapia.ai’s analytics tool, gives you real-time visibility into representation, inclusion, and fairness at every stage of your talent funnel. It helps you connect the dots between your attraction strategies and actual hiring outcomes.

Key features include:

  • Demographic filters – Switch between gender, ethnicity, English as an additional language, First Nations status, disability, and veteran status. View age and ethnicity in standard or alternative formats to match regional reporting needs.
  • Representation highlights – Identify the top five represented sub-groups for each demographic, plus the three fastest-growing among underrepresented groups.
  • Track trends over time – See month-by-month changes in representation over the past 12 months, compare to earlier periods, and connect the data back to your EVP and attraction spend.
  • Candidate experience metrics – Measure CSAT (satisfaction) and engagement rates by demographic to ensure your hiring process works for everyone. Inclusion is measurable.
  • Hiring fairness – Compare representation in your applied, recommended, and hired pools to spot drop-offs. Understand not just who applies, but who progresses — and why.

     

From insight to action

With the Diversity Dashboard, you can pinpoint where inclusion is thriving and where it’s falling short.

  • See if your EASL candidates are applying in high numbers but not progressing to live interview.
  • Spot if candidates with a disability report high satisfaction but have lower offer rates.
  • Track the impact of targeted campaigns month-by-month and adjust quickly when something isn’t working.

It’s also a powerful tool to tell your success story. Celebrate wins by showing which underrepresented groups are making the biggest gains, and share that progress with boards, executives, and regulators.

Built on science, backed by trust

Powered by explainable AI and the world’s largest structured interview dataset, your insights are fair, auditable, and evidence-based.

Measuring diversity is the first step. Using that data to take action is where you close the Diversity Gap. With the Diversity Dashboard, you can prove your strategy is working and make the changes where it isn’t.

Book a demo to see the Diversity Dashboard in action.

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Neuroinclusion by design. Not by exception.

Why neuroinclusion can’t be a retrofit and how Sapia.ai is building a better experience for every candidate.

In the past, if you were neurodivergent and applying for a job, you were often asked to disclose your diagnosis to get a basic accommodation – extra time on a test, maybe the option to skip a task. That disclosure often came with risk: of judgment, of stigma, or just being seen as different.

This wasn’t inclusion. It was bureaucracy. And it made neurodiverse candidates carry the burden of fitting in.

We’ve come a long way, but we’re not there yet.

Shifting from retrofits to inclusive-by-design

Over the last two decades, hiring practices have slowly moved away from reactive accommodations toward proactive, human-centric design. Leading employers began experimenting with:

  • Sharing interview questions in advance

  • Replacing group exercises with structured simulations

  • Offering a variety of assessment formats

  • Co-designing assessments with neurodiverse candidates

But even these advances have often been limited in scope, applied to special hiring programs or specific roles. Neurodiverse talent still encounters systems built for neurotypical profiles, with limited flexibility and a heavy dose of social performance pressure.

Hiring needs to look different.

Insight 1: The next frontier of hiring equity is universal design

Truly inclusive hiring doesn’t rely on diagnosis or disclosure. It doesn’t just give a select few special treatment. It’s about removing friction for everyone, especially those who’ve historically been excluded.

That’s why Sapia.ai was built with universal design principles from day one.

Here’s what that looks like in practice:

  • No time limits — Candidates answer at their own pace
  • No pressure to perform — It’s a conversation, not a spotlight
  • No video, no group tasks — Just structured, 1:1 chat-based interviews
  • Built-in coaching — Everyone gets personalised feedback

It’s not a workaround. It’s a rework.

Insight 2: Not all “friendly” methods are inclusive

We tend to assume that social or “casual” interview formats make people comfortable. But for many neurodiverse individuals, icebreakers, group exercises, and informal chats are the problem, not the solution.

When we asked 6,000 neurodiverse candidates about their experience using Sapia.ai’s chat-based interview, they told us:

“It felt very 1:1 and trustworthy… I had time to fully think about my answers.”

“It was less anxiety-inducing than video interviews.”

“I like that all applicants get initial interviews which ensures an unbiased and fair way to weigh-up candidates.”

Insight 3: Prediction ≠ Inclusion

Some AI systems claim to infer skills or fit from resumes or behavioural data. But if the training data is biased or the experience itself is exclusionary, you’re just replicating the same inequity with more speed and scale.

Inclusion means seeing people for who they are, not who they resemble in your data set.

At Sapia.ai, every interaction is transparent, explainable, and scientifically validated. We use structured, fair assessments that work for all brains, not just neurotypical ones.

Where to from here?

Neurodiversity is rising in both awareness and representation. However, inclusion won’t scale unless the systems behind hiring change as well.

That’s why we built a platform that:

  • Doesn’t rely on disclosure

  • Removes ambiguity and pressure

  • Creates space for everyone to shine

  • Measures what matters, fairly

Sapia.ai is already powering inclusive, structured, and scalable hiring for global employers like BT Group, Costa Coffee and Concentrix. Want to see how your hiring process can be more inclusive for neurodivergent individuals? Let’s chat. 

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