NYC Local Law 144 Compliance & AI Implementation Strategy This strategy is designed for The Fortune Society to modernize its hiring process while strictly avoiding the "Automated Employment Decision Tool" (AEDT) classification under NYC Local Law 144. By focusing on administrative and summarization tools rather than ranking or scoring systems, the organization can scale its 500-application/month workload without the financial and legal burden of a mandatory independent bias audit. Compliance Roadmap: Audit-Avoidance Strategy A. Defining the "Safe Zone" (Non-AEDT Use Cases) To avoid the AEDT designation, AI must not "substantially assist or replace" discretionary decision-making. Permitted: AI used for job description optimization (removing gendered language), interview note summarization (converting audio/text to bullet points), and scheduling. These are administrative. Prohibited (without audit): AI that assigns a numerical score to resumes, ranks candidates in a "top 10" list, or automatically filters out candidates based on keyword matching. B. The 10-Business-Day Notification Requirement Even if a tool is not an AEDT, transparency is a core requirement of the DCWP 2026 guidance. The Fortune Society must notify candidates at least 10 business days before the tool is used. Since applications are received via email, an automated "Application Received" reply containing the required disclosures satisfies this timeline before any AI summarization occurs. C. Alternative Selection Processes Candidates have the right to opt-out of AI involvement. The Fortune Society’s existing manual scorecard is the perfect "alternative process." If a candidate opts out of AI summarization, their resume and interview notes are processed manually by the HR lead using the exact same evaluation criteria as the AI-assisted path, ensuring equity without technical bias. D. Disclosure Language Standards Under 2026 enforcement rules, disclosures must be "clear and conspicuous." Job Postings: Must state that AI is used and link to a more detailed policy. Direct Communications: Must specify the data being collected (e.g., "text from your resume") and the specific tool category (e.g., "generative summarization"). E. Data Readiness (The "Zero-Data" Constraint) Because the organization lacks six months of historical hiring data, it cannot currently perform a "Bias Ratio" calculation (required for AEDTs). If The Fortune Society chooses to adopt ranking tools in the future, they should begin using synthetic data—simulated candidate profiles—to test their scorecards for disparate impact now, building a "pre-compliance" baseline. AI Tool Comparison & Compliance Evaluation Tool Category Example Tools Triggers AEDT? Primary Function Time Savings (500 apps/mo) Bias Risk Cost Tier JD Optimization Textio, Ongig No Removes bias from job ads Low (Pre-hire) Very Low Mid Sourcing Assistant LinkedIn Recruiter AI No* Identifies potential leads High (Top of funnel) Low High Note Summarization Otter.ai, Notion AI No Transcribes/summarizes interviews High (Post-interview) Low Low Ranking/Screening Workday, HireVue YES Scores/ranks resumes Very High High High \Note: Sourcing tools are generally exempt if they do not provide a "recommendation" to hire/reject, but rather just surface available profiles.* Compliant AI-Assisted Hiring Workflow Workflow Explanation: The AI "touches" the process only to clean up job descriptions and summarize interview notes. At no point does the AI say "Hire this person." The HR Lead remains the sole arbiter of the "Hire/No-Hire" decision, ensuring the tool remains a "support" function rather than an "automated decision" function. Disclosure Templates Template 1: Job Posting Disclosure (External) Employment Technology Disclosure The Fortune Society utilizes [Tool Name] to assist in the administrative processing of job applications. This tool is used solely for [summarizing interview notes / optimizing job descriptions] and does not rank, score, or make automated decisions regarding your candidacy. All hiring decisions are made by human staff. You may request an alternative application process by contacting our HR Lead at [HR Contact Email]. Template 2: Candidate Notification Email (Sent within 10 days of receipt) Subject: Update regarding your application to The Fortune Society Dear [Candidate Name], Thank you for your interest in The Fortune Society. To ensure a timely and thorough review of your application, we wish to inform you that we utilize [Tool Name], an artificial intelligence tool, as part of our recruitment process. Type of Tool: Administrative Summarization. Data Processed: Information provided in your resume and notes from your interview. Purpose: To assist our HR lead in organizing candidate information for human review. Under NYC Local Law 144, you have the right to request an alternative selection process or a manual review of your materials. If you wish to opt-out of the use of this tool, please reply to this email or contact [HR Lead Name] at [HR Contact Email] within 3 business days. If you opt-out, your application will be reviewed manually using our standardized candidate scorecard. Implementation Recommendations (90-Day Roadmap) Standardize the Manual Scorecard (Days 1-30): Before introducing AI, the HR lead must formalize a rubric for all roles. This ensures that if a candidate opts out of AI, the "alternative process" is ready, objective, and defensible. Deploy "Safe" Summarization Tools (Days 31-60): Implement a tool like Notion AI or Otter.ai specifically for interview summarization. This addresses the heaviest administrative lift (500 applications) without triggering AEDT status, as it merely reformats human-gathered data. Automate Disclosure via Email (Days 61-90): Set up an automated "Rules" or "Auto-reply" function in the HR email inbox. This ensures every candidate receives the NYC-mandated 10-day notice immediately upon application, satisfying DCWP transparency requirements with zero manual effort.