Implementing Bias Audits in Vendor Contracts and Internal Policies for AI Hiring Tools: Strategies for Transparency and Risk Mitigation

Since July 2023, New York City has mandated independent bias audits for any Automated Employment Decision Tool (AEDT) used in hiring, under Local Law 144. Recent research has shown how these audits can reveal data limitations, bias metrics, and unreliable drivers, emphasizing that legal compliance is merely the first step towards fairness. HR teams that rely on AI hiring must now collaborate with tech, legal, and external auditors to ensure transparency and risk mitigation. If left unchecked, automated systems could backfire. How can HR integrate bias audits into vendor contracts and internal policies around hiring tools? What communication strategies can be used to maintain transparency while avoiding perceptions of tokenism?

Integrating bias audits into vendor contracts and internal policies for AI hiring tools requires a multi-faceted approach:

1. Vendor Contracts: Ensure that the contracts with vendors who provide AI hiring tools include clauses for regular bias audits. This could involve third-party audits or audits conducted by the vendor themselves, provided they have the necessary expertise. The contract should specify the frequency of audits, the metrics to be evaluated, and the actions to be taken if bias is detected.

2. Internal Policies: Develop and implement internal policies that mandate bias audits for all AI hiring tools used within the organization. These policies should clearly define the audit process, the roles and responsibilities of all involved parties, and the steps to be taken to address any identified bias.

Communication strategies to maintain transparency while avoiding perceptions of tokenism could include:

1. Open Dialogue: Foster an open dialogue about the use of AI in hiring and the potential for bias. This can be achieved through regular team meetings, newsletters, or internal webinars.

2. Training: Provide training to all employees on how AI hiring tools work, the potential for bias, and the measures being taken to mitigate this risk. This will help to demystify the technology and demonstrate the organization's commitment to fairness.

3. Reporting: Regularly report on the outcomes of bias audits and the actions taken in response. This will demonstrate the organization's commitment to transparency and continuous improvement.

Remember, the goal is not just to comply with the law, but to genuinely ensure fairness in hiring practices. This requires ongoing effort and commitment from all levels of the organization.