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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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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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Skills Measurement vs Skills Inference – What’s the Difference and Why Does It Matter?

There’s growing interest in AI-driven tools that infer skills from CVs, LinkedIn profiles, and other passive data sources. These systems claim to map someone’s capability based on the words they use, the jobs they’ve held, and patterns derived from millions of similar profiles. In theory, it’s efficient. But when inference becomes the primary basis for hiring or promotion, we need to scrutinise what’s actually being measured and what’s not.

Let’s be clear: the technology isn’t the problem. Modern inference engines use advanced natural language processing, embeddings, and knowledge graphs. The science behind them is genuinely impressive. And when they’re used alongside richer sources of data, such as internal project contributions, validated assessments, or behavioural evidence, they can offer valuable insight for workforce planning and development.

But we need to separate the two ideas:

  • Skills Measurement: Directly observing or quantifying a skill based on evidence of actual performance. 
  • Skills Inference: Estimating the likelihood that someone has a skill, based on indirect signals or patterns in their data. 

The risk lies in conflating the two.

The Problem Isn’t Inference of Skills. It’s the Data Feeding It

CVs and LinkedIn profiles are riddled with bias, inconsistency, and omission. They’re self-authored, unverified, and often written strategically – for example, to enhance certain experiences or downplay others in response to a job ad. 

And different groups represent themselves in different ways. Ahuja (2024) showed, for example, that male MBA graduates in India tend to self-promote more than their female peers. Something as simple as a longer LinkedIn ‘About’ section becomes a proxy for perceived competence.

Job titles are vague. Skill descriptions vary. Proficiency is rarely signposted. Even where systems draw on internal performance data, the quality is often questionable. Ratings tend to cluster (remember the year everyone got a ‘3’ at your org?) and can often reflect manager bias or company culture more than actual output.

Sophisticated ≠ Objective

The most advanced skill inference platforms use layered data: open web sources like job ads and bios, public databases like O*NET and ESCO, internal frameworks, even anonymised behavioural signals from platform users. This breadth gives a more complete picture, and the models powering it are undeniably sophisticated.

But sophistication doesn’t equal accuracy.

These systems rely heavily on proxies and correlations, rather than observed behaviour. They estimate presence, not proficiency. And when used in high-stakes decisions, that distinction matters.

Transparency (or Lack Thereof)

In many inference systems, it’s hard to trace where a skill came from. Was it picked up from a keyword? Assumed from a job title? Correlated with others in similar roles? The logic is rarely visible, and that’s a problem, especially when decisions based on these inferences affect access to jobs, development, or promotion.

Presence ≠ Proficiency

Inferred skills suggest someone might have a capability. But hiring isn’t about possibility. It’s about evidence of capability. Saying you’ve led a team isn’t the same as doing it well. Collecting or observing actual examples of behaviour allows you to evaluate someone’s true competence at a claimed skill. 

Some platforms try to infer proficiency, too, but this is still inference, not measurement. No matter how smart the model, it’s still drawing conclusions from indirect data.

By contrast, validated assessments like structured interviews, simulations, and psychometric tools are designed to measure. They observe behaviour against defined criteria, use consistent scoring frameworks (like Behaviourally Anchored Rating Scales, or BARS), and provide a transparent, defensible basis for decision-making. In doing this, the level or proficiency of a skill can be placed on a properly calibrated scale. 

But here’s the thing: we don’t have to choose one over the other.

A Smarter Way Forward: The Hybrid Model

The real opportunity lies in combining the rigour of measurement with the scalability of inference.

Start with measurement
Define the skills that matter. Use structured tools to capture behavioural evidence. Set a clear standard for what good looks like. For example, define Behaviourally Anchored Rating Scales (BARS) when assessing interviews for skills. Using a framework like Sapia.ai’s Competency Framework is critical for defining what you want to measure. 

Layer in inference
Apply AI to scale scoring, add contextual nuance, and detect deeper patterns that human assessors might miss, especially when reviewing large volumes of data.

Anchor the whole system in transparency and validation
Ensure people understand how inferences are made by providing clear explanations. Continuously test for fairness. Keep human oversight in the loop, especially where the stakes are high. More information on ensuring AI systems are transparent can be found in this paper.

This hybrid model respects the strengths and limits of both approaches. It recognises that AI can’t replace human judgement, but it can enhance it. That inference can extend reach, but only measurement can give you higher confidence in the results.

The Bottom Line

Inference can support and guide, but only measurement can prove. And when people’s futures are on the line, proof should always win.

References

Ahuja, A. (2024). LinkedIn profile analysis reveals gender-based differences in self-presentation among Indian MBA graduates. Journal of Business and Psychology.

 

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Making Healthcare Hiring Human with Ethical AI

Hiring for care is unlike any other sector. Recruiters are looking for people who can bring empathy, resilience, and energy to the most demanding human roles. Whether it’s dental care, mental health, or aged care, new hires are charged with looking after others when they’re most vulnerable. The stakes are high. 

Hiring for care is exactly where leveraging ethical AI can make the biggest impact.

Hiring for the traits that matter

The best carers don’t always have the best CVs.

That’s why our chat-based AI interview doesn’t screen for qualifications. It screens for the the skills that matter when caring for others. The traits that define a brilliant care worker, things like:

Empathy, Self-awareness, Accountability, Teamwork, and Energy. 

The best way to uncover these traits is through structured behavioural science, delivered through an experience that allows candidates to open up. Giving candidates space to give real-life, open-text answers. With no time pressure or video stress. Then, our AI picks up the signals that matter, free from any demographic data or bias-inducing signals.

Candidates’ answers to our structured interview questions aren’t simply ticking boxes. They’re a window into how someone shows up under pressure. And they’re helping leading care organisations hire people who belong in care and those who stay.

Inclusion, built in

Inclusivity should be a core foundation of any talent assessment, and it’s a fundamental requirement for hirers in the care industry. 

When healthcare hirers use chat-based AI interviews, designed to be inclusive for all groups, candidates complete their interviews when and where they choose, without the bias traps of face-to-face or phone screening. There are no accents to judge, no assumptions, just their words and their story.

And it works:

  • 91.8% of carer candidates complete their interviews
  • Carer candidates report 9/10 Candidate Satisfaction with their interview experience 
  • 80% of candidates would recommend others to apply 
  • Every candidate receives personalised feedback, regardless of the outcome

Drop-offs are reduced, and engagement & employer brand advocacy go up. Building a brand that candidates want to work for includes providing a hiring experience that candidates want to complete. 

Real outcomes in care hiring

Our smart chat already works for some of the most respected names in healthcare and community services. Here’s a sample of the outcomes that are possible by leveraging ethical AI, a validated scientific assessment, wrapped in an experience that candidates love: 

Anglicare – a leading provider of aged care services
  • Time-to-offer dropped from 40+ days to just 14
  • Candidate pool grew by 30%
  • Turnover dropped by 63%
Abano Healthcare – Australasia’s largest dental support organisation
  • 1,213 recruiter hours saved  in the first month (67 hours per individual hiring team member) 
  • $25,000 saved in screening and interviewing time
Berry Street – a not for profit family & child services organisation
  • Time-to-hire down from 22 to 7 days
  • 95.4% of candidates completed their chat interviews

A smarter way to hire

The case study tells the full story of how Sapia.ai helped Anglicare, Abano Healthcare, and Berry Street transform their hiring processes by scaling up, reducing burnout, and hiring with heart. 

Download it here:

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