Why Olivia is uniquely complex under the EU AI Act
Most recruiting tools are asynchronous: a candidate submits a CV, software scores it overnight, a recruiter sees the score the next morning. Olivia is real-time and conversational — candidates interact with it directly, often not knowing it is AI. This creates the Article 50 obligation immediately.
At the same time, Olivia's conversations are structured screening — it asks qualifying questions, assesses answers, and makes autonomous scheduling decisions (or withholds scheduling from candidates who do not qualify). This is employment screening. The conversation is not neutral data collection; it is AI-based gatekeeping. That is Annex III Category 4.
The scheduling decision as screening
A subtle but important point: Olivia's decision about who gets an interview slot and who does not is itself a high-risk AI decision. Even if Olivia is just asking availability questions and forwarding everyone who responds — that automatic forwarding decision is the AI taking an action that affects who progresses through a hiring process. If the forwarding is conditional on any screening criterion (keyword in a response, score threshold, availability match), that conditionality is high-risk screening.