How Sympa supports AI Act compliance

Overview

Focus AI is Sympa's AI-powered assistant for the Sympa HR platform.

Focus AI allows authorised HR users to ask questions about HR data in ordinary written language, instead of manually building searches or filters. It helps users find and review information already available to them in Sympa.

Focus AI is not a general-purpose chatbot. It is limited to supported HR-related use cases made available within Sympa. Any future HR policy Q&A functionality will be assessed and documented separately before release. Focus AI does not replace human judgement, HR decision-making, legal assessment, official reporting, or the customer's internal HR processes.

This information reflects the current Focus AI functionality, intended use and limitations as described on this page. Sympa may update this information if Focus AI’s functionality, intended use, user groups, output types, integrations or data processing materially change. 

Availability

Focus AI is an optional add-on feature.

It is not enabled by default and requires a separate agreement and activation process before it is made available to a customer.

Customers decide whether to enable Focus AI for their organisation. Access is initially intended for authorised HR administrators or similarly authorised users.

Broader access based on roles and permissions may be introduced in the future.

EU AI Act and Focus AI

What is the EU AI Act?

The EU AI Act is the EU's legal framework for the development, placing on the market, and use of AI systems. It follows a risk-based approach and sets different obligations depending on the intended purpose and risk level of the AI system.

Because Focus AI is used in an HR environment, Sympa has assessed it against the EU AI Act framework, including the rules concerning employment and worker-management AI systems.

Sympa's AI Act assessment

In its current intended use, Sympa does not consider Focus AI to be a high-risk AI system under the EU AI Act.

This assessment is based on Focus AI’s current intended use: factual HR data search, sorting, filtering, joining and visualisation. Focus AI is not designed or intended to make, recommend or substantially influence decisions concerning recruitment, selection, promotion, termination, salary, benefits, disciplinary action, task allocation, performance evaluation, suitability, potential, conduct or value of any individual. 

Focus AI is designed to support HR data search, sorting, filtering, limited visualisation and navigation only. It is not intended to make, recommend, or substantially influence decisions about individuals.

Focus AI is not intended to:

• make decisions affecting employees or candidates;
• recommend recruitment, promotion, termination, salary changes, disciplinary action, or task allocation;
• evaluate, score, profile, or monitor employees;
• assess performance, suitability, potential, conduct, or value;
• replace human HR decision-making.

Some Focus AI outputs may involve sensitive HR contexts, such as compensation, competence assessment data, age, tenure, legal gender, language, location or organisational information. These outputs are provided as factual search, sorting or visualisation results only. They must not be treated as recommendations, assessments or decisions about individuals. 

Focus AI helps authorised users find information already available to them in Sympa. It does not decide what should be done with that information. 

What Sympa has done to support AI Act compliance

Sympa has designed Focus AI with the following safeguards:

• Focus AI is optional and requires separate activation.
• Focus AI has a defined and limited intended purpose.
• Focus AI is limited to HR data search, sorting, filtering, limited visualisation and navigation.
• Focus AI does not make or recommend employment decisions.
• Focus AI does not create, update, or delete HR data in its current scope.
• Focus AI operates under existing Sympa access controls.
• Users are informed that they are using an AI-powered feature.
• Users remain responsible for reviewing and validating outputs.
• Customer HR records are not used for AI model training or model improvement.
• Sympa reassesses the AI Act classification if the functionality materially changes.

Employment-context safeguards

Focus AI operates in an HR context. Sympa recognises that HR data search results could be misused if users relied on them improperly in employment-related decisions.

For this reason, Focus AI must not be used as the sole basis for decisions affecting employees, candidates, contractors, or other individuals.

Any HR decision must be made by authorised human users through the customer's normal HR processes, with appropriate review and validation.

Focus AI outputs should be treated as search assistance, not as HR recommendations or decisions.

This applies especially where Focus AI outputs relate to compensation, salary progression, competence or skill assessments, age, tenure, legal gender, organisational membership, or other sensitive HR contexts.

Reassessment of AI Act classification

Sympa reassesses the AI Act classification of Focus AI when there is a material change in:

• functionality;
• intended use;
• user groups;
• output types;
• level of autonomy;
• data processed;
• integration with HR workflows;
• ability to create, update, or delete HR data;
• any feature that could make or substantially influence employment-related decisions.

Sympa will reassess Focus AI’s AI Act classification if Focus AI’s functionality, intended purpose, output types, autonomy level, user groups, data processed or workflow integrations materially change. 

If Focus AI evolves toward functionality that may be classified as high-risk under the EU AI Act, Sympa will complete the required assessment and compliance steps before releasing such functionality.

What Focus AI can do?

Focus AI helps authorised users search, sort, filter, visualise and review HR data already available in Sympa.

Focus AI lets authorised users query existing HR data using ordinary written language. The role of the language model (LLM) is limited to interpreting the user's question and translating it into structured calls to backend APIs. The underlying HR data is retrieved, filtered, sorted, and calculated deterministically by those backend systems — it is not read, processed, generated, or evaluated by the AI. Results are factual records drawn from authorised data sources, presented to the user for their own review and decisions.

1. Natural-language access

• Ask questions about HR data in ordinary written language.
• Ask follow-up questions that refine, reset, or add criteria, or that show, hide, or remove result columns.
• See live progress while the system interprets the request, calls tools, searches authorised data sources, and composes the answer.

2. Supported search and filtering 

Users can find and filter records across the following data domains, using only structured criteria already held in the system: 

• People and organisational data by employee attributes grouped as: identity and contact details (name, preferred name, email, phone, address, city, zip, language); role and organisation (job title, organisational unit, team or department, job group); employment timeline (hire date, tenure, seniority, years of service); employment terms (contract type and category, working-time type, payment group, work country); and demographic fields (legal gender, birth date or age), subject to user access rights.
• Compensation data by factual criteria such as amount, currency, compensation category and type, benefits and benefit amounts, bonuses, and compensation begin/end date ranges.
• Competence and skills data retrieving existing assessment records including skills, skill sets, and current and target levels, where available.
• Combined queries supported people, compensation, and competence criteria can be combined in a single question.

3. Presenting and exploring results 

• Return people results as interactive lists with columns selected dynamically based on the question, including skill-related columns for competence queries.
• Sort results by visible factual columns in ascending or descending order, including derived factual values such as salary change over a stated period.
• Compare salary progression over an explicit time period, calculated from available compensation records.
• View limited scatter-plot visualisations for supported numeric metrics such as salary, age, and tenure/years of service.
• Open employee profiles directly from result-list rows or scatter-plot points.

4. User control over results (human oversight) 

• Remove people from a result list and carry those exclusions into follow-up questions.
• Add, refine, or reset criteria and adjust visible columns across successive questions.

5. Transparency and result safeguards 

• A remark is shown when the maximum result count is exceeded and only a partial result set is returned.
• A multi-currency remark is shown when results contain multiple currencies that should not be compared as a single unit.
• Live progress is shown throughout interpretation and retrieval (also listed under natural-language access).

What Focus AI does not do

Focus AI does not make, recommend, automate or rank options for HR decisions.

Focus AI does not evaluate, score, profile or monitor employees, and it does not create, update or delete HR data.

Focus AI does not create skill assessments, infer new skills, recommend training plans, perform dedicated competence or skills-gap analysis workflows, or decide whether an employee is qualified for a role or task.

Focus AI does not recommend salary changes, bonuses, compensation decisions, promotions, demotions, disciplinary actions, contract renewals, task allocation, or other employment-related outcomes.

Focus AI is not intended for recruitment decisions, promotion decisions, termination decisions, salary decisions, disciplinary decisions, task allocation, performance evaluation, legal advice, HR policy interpretation, official reporting, or general-purpose chatbot use.

How Focus AI works

When a user asks a question, Focus AI interprets the question and converts it into structured search instructions.

The AI model does not connect to, search, or access the customer's HR database. If a user includes personal data in a prompt, that prompt is processed by the AI component for interpretation in accordance with this Trust Centre page and the applicable agreement. This does not mean that the AI model directly connects to or retrieves records from the Customer’s HR database.

Sympa's own platform retrieves the relevant HR data using the customer's existing tenant, user, and access-control rules.

The result is then shown to the authorised user inside Sympa.

In simplified form:

1. The user asks a question in Focus AI.

2. The AI interprets the question.

3. The AI creates structured search instructions.

4. Sympa's platform executes the search under existing access controls.

5. The result is shown to the authorised user.

Focus AI does not expand a user's access rights. If a user cannot access certain data in Sympa, Focus AI cannot be used to access that data.

Sensitive HR data and visualisations

Focus AI may retrieve or visualise certain sensitive HR contexts, such as compensation, competence assessment data, age, tenure, legal gender, language, location or organisational information, where such data is available in Sympa and the user is authorised to access it.

These outputs are provided only as factual search, sorting or visualisation results. They must not be used to make or support discriminatory decisions, or to rank, assess, exclude, select or treat individuals differently on prohibited or inappropriate grounds.

Scatter plots and other supported visualisations are intended to help users review data patterns. They are not official HR analytics, KPI reporting, pay equity analysis, discrimination analysis, competence-gap analysis, or employment decision recommendations.

Scatter plots and visualisations should be interpreted carefully and verified against source data. They may reflect incomplete data, capped result sets, multi-currency compensation data, or limitations in available fields.

Proper use of Focus AI

Focus AI is intended to help authorised HR users find and review HR information stored in Sympa.

Focus AI must not be used to make, recommend, or substantially influence decisions about employees or candidates. This includes decisions about recruitment, promotion, termination, salary changes, disciplinary action, task allocation, or performance evaluation.

Users must verify important outputs against the source data in Sympa before relying on them.

Focus AI outputs should be treated as search assistance, not as HR recommendations, assessments, analytics conclusions, or decisions.

Where Focus AI returns compensation, competence, age, tenure, legal gender or visualisation results, users must take particular care to ensure that the outputs are used lawfully, proportionately, and only for appropriate HR purposes.

Accuracy and limitations

Focus AI may produce outputs that contain errors, omissions, incomplete results, or misinterpretations of the user's question.

The quality of outputs may depend on:

• the clarity of the user's question;
• the completeness and accuracy of the underlying HR data;
• the fields currently supported by Focus AI;
• the user's permissions;
• system configuration;

Focus AI does not guarantee that results are complete, correct, or suitable for a particular decision or legal purpose.

Users must verify important information against the source data in Sympa before relying on it.

Some result sets may be capped. Focus AI may show a remark where a default-capped result set or cross-domain selector has been truncated.

Compensation data may involve multiple currencies. Where salary results include multiple currencies, Focus AI may show a remark that the values should not be compared as one unit.

Monthly and annual salary conversions depend on supported compensation data and connector logic and should be verified against source records.

Scatter plots are limited to supported metrics and supported payloads. Focus AI does not generate arbitrary BI dashboards, official KPI reporting, pay equity analysis, discrimination analysis, or unrestricted chart types.

Human oversight

Focus AI is designed to support HR professionals, not to replace them.

Users remain responsible for:

• reviewing Focus AI outputs critically;
• checking whether the question was interpreted correctly;
• verifying important results against the source data in Sympa;
• confirming that the result is suitable for the intended purpose;
• applying the customer's normal HR processes;
• escalating legal, employment, or data protection questions through normal internal channels.

Focus AI outputs should not be used without appropriate human review.

Human review is especially important where outputs involve compensation, competence, age, tenure, legal gender, organisational membership, or visualisations.

Privacy and data protection

How prompts and HR data are handled

Focus AI processes the user's prompt, meaning the question or instruction entered by the user.

Focus AI is designed so that users can ask questions about HR data without copying HR records into the prompt.

Users should not enter unnecessary personal data, sensitive information, or large extracts of HR records into Focus AI questions.

If a Customer’s user includes personal data in a prompt, this is Customer-controlled input. Sympa may process prompts and operational metadata to provide, secure, monitor, troubleshoot, support and improve Focus AI, including identifying unsupported, unclear or unsuccessful requests, in accordance with the applicable agreement. This does not mean that Customer HR records, Focus AI prompts or Focus AI outputs are used to train, fine-tune or improve AI models. 

The AI model does not connect to or search the customer's HR database. Sympa's own platform retrieves HR data under the customer's existing tenant, user, and access-control rules.

Customer HR records

Customer HR records remain in Sympa's platform.

Customer HR records are not used by Sympa or Microsoft Azure OpenAI for AI model training or model improvement.

Customer HR records are not copied into AI models.

Data from one Sympa customer is not used to train, improve, or influence AI functionality for another customer.

AI model training

Focus AI does not use customer HR records to train AI models. Customer HR records, Focus AI prompts and Focus AI outputs are not used by Sympa or Microsoft Azure OpenAI to train, fine-tune or improve AI models.

Customer HR records are not used by Sympa or Microsoft Azure OpenAI for AI model training or model improvement.

If a user includes personal data in a Focus AI prompt, the prompt is processed only to provide the service and is not used for AI model training.

GDPR roles

For customer HR data processed in the Sympa HR platform, the customer is generally the data controller and Sympa acts as data processor under the applicable Data Processing Agreement.

Where Microsoft Azure OpenAI is used to provide the AI component, Microsoft acts as Sympa's subprocessor for the relevant processing activities.

Data location

Focus AI is designed so that relevant processing takes place within the European Union.

Retention

Focus AI does not store customer HR records in the AI model.

Focus AI may store operational metadata and logs necessary for service operation, security, troubleshooting, abuse prevention, monitoring, and auditability.

Depending on configuration, this may include:

• user identifiers;
• tenant identifiers;
• timestamps;
• request identifiers;
• prompt text;
• generated structured search instructions;
• status information;
• error information.

Logs and operational metadata are retained in accordance with Sympa's applicable logging, retention, security, and data protection practices. Retention periods depend on the applicable log category and are described in Sympa’s applicable documentation or otherwise made available to the Customer.

Individual rights

Data subject rights, such as access, rectification, and erasure, apply to personal data held in the Sympa platform.

Individuals wishing to exercise their rights should contact their employer, HR department, or the relevant Sympa customer acting as controller.

Sympa supports customers in handling data subject requests in accordance with the applicable Data Processing Agreement.

Security and access control

Focus AI operates within the customer's existing access-control model.

A user cannot use Focus AI to access data that they are not authorised to access in Sympa.

In the current phase, Focus AI is intended for admin-style access together with existing downstream service authorisation. More granular manager- or unit-scoped access is not part of the current scope unless separately introduced.

Focus AI does not expand the user's underlying permissions. The same tenant, user, and downstream service authorisation rules apply when data is retrieved through Focus AI.

Sympa protects Focus AI through security measures such as:

• encryption in transit;
• tenant-based access controls;
• user authentication and authorisation;
• secure infrastructure;
• monitoring and logging;
• supplier security management.

Sympa's security practices follow recognised industry standards.

Logging and traceability

Focus AI maintains operational logs for security, troubleshooting, abuse prevention, service monitoring, and auditability purposes.

Depending on configuration and applicable retention practices, logs may include:

• user and tenant identifiers;
• timestamps;
• request identifiers;
• prompt text;
• generated structured search instructions;
• backend status information;
• error information.

Logs are protected under Sympa's security controls and handled in accordance with applicable data protection requirements.

Customer-facing log access or export functionality will be described separately where available. Focus AI logs and operational metadata are used for service operation, security, troubleshooting, abuse prevention, monitoring, auditability and improving Focus AI functionality. Where possible, Sympa uses aggregated or limited information for product development purposes.

Responsible AI principles

Human control

AI in Sympa is a tool that supports HR professionals. It does not make decisions on their behalf.

Focus AI outputs can be reviewed, ignored, refined, or rejected by users.

Transparency

Users are informed when they are using Focus AI.

Focus AI is clearly identified as an AI-powered feature within the Sympa interface.

Sympa provides documentation explaining how Focus AI works, what it is intended for, what data is involved, what limitations apply, and how customers should oversee its use.

Sympa supports AI literacy by providing information on Focus AI’s intended use, limitations, proper use and prohibited use. 

No use of customer HR data for AI model training

Sympa does not use customer HR records to train or improve AI models.

Customer HR records are used only to provide the service in accordance with the applicable agreement.

Data protection and security

Data protection and security are core requirements in the design of Focus AI.

Focus AI is designed to:

• use existing Sympa access controls;
• limit the role of the AI model;
• avoid unnecessary inclusion of personal data in prompts;
• prevent use of customer HR records for AI model training;
• support secure operation, monitoring, and troubleshooting.

Fairness and bias

Focus AI is not intended to evaluate employees, assess suitability, or generate recommendations about individuals.

However, outputs may still reflect limitations or biases in:

• the underlying HR data;
• the user's question;
• system configuration;
• supported fields;
• query interpretation;
• how results are sorted or presented.

Users must not treat Focus AI outputs as assessments of an employee's value, performance, suitability, conduct, or potential.

Customers are responsible for ensuring that searches, filters, sorting, comparisons and visualisations are not used for discriminatory or otherwise unlawful purposes.

Reliability

Focus AI is designed to provide useful assistance based on data available in Sympa, but it may make mistakes.

Outputs may contain errors, omissions, incomplete results, or misinterpretations.

Users should verify important information before relying on it.

Accountability

Sympa is responsible for the design and provision of Focus AI.

Customers are responsible for deciding how Focus AI is used within their organisation, who may access it, and how outputs are reviewed and governed in their HR processes.

Customer responsibilities

Customers using Focus AI are responsible for:

• deciding whether to enable Focus AI;
• assessing whether the Customer’s use of Focus AI requires a DPIA, employee notice, worker representative consultation or other customer-side assessment or notice; 
• deciding which users should have access;
• ensuring that access rights are appropriate;
• ensuring that users receive appropriate instructions before using Focus AI; 
• instructing users not to include unnecessary personal data in prompts;
• ensuring that users review and verify outputs;
• ensuring that Focus AI is not used as the sole basis for decisions affecting individuals;
• ensuring that compensation, competence, age, tenure, legal gender and visualisation outputs are used lawfully and appropriately;
• ensuring that Focus AI is not used to make or support discriminatory decisions;
• assessing whether their intended use creates additional obligations under the EU AI Act, GDPR, labour law, or internal governance rules;
• complying with any applicable information or consultation duties toward employees or employee representatives.

For purposes of the EU AI Act, Sympa acts as the provider of Focus AI and customers using Focus AI generally act as deployers.

Microsoft Azure OpenAI acts as a technology supplier/subprocessor in the AI supply chain, not as the provider of Focus AI to Sympa's customers.

Frequently asked questions