Last Updated: 20th April 2026 Governing Law: England and Wales
These terms constitute a formal update to the VacanCV Terms of Service, specifically addressing the deployment of agentic AI recruiter technologies and compliance with the UK Data Use and Access Act (DUAA) 2025.
1. AI Behavioral & EQ Analysis (Sarah 3.1 Frontier Suite)
The Sarah 3.1 Forensic Intelligence Engine utilizes advanced sentiment, tonal, and linguistic analysis to evaluate candidate "cultural fit" and Emotional Intelligence (EQ).
Interpretive Nature: Users acknowledge that EQ scores and "cultural vibe" assessments provided by the Service are subjective, interpretive outputs based on algorithmic patterns. They do not constitute a definitive psychological or professional evaluation.
Bias Mitigation & Responsibility: While VacanCV employs industry-leading bias-reduction protocols, the Business remains the sole decision-maker. VacanCV shall not be liable for any claims of discrimination or bias arising from a Business's reliance on Sarah 3.1 scores.
Neurodiversity & Accents: Candidates and Businesses acknowledge that AI evaluation of voice and tone may vary based on accent, speech patterns, or neurodivergent traits. All Sarah 3.1 outputs must be verified by a human recruiter during the "Human-in-the-Loop" gate.
2. Autonomous Outreach & Lead Generation (Sarah Reach)
The "Sarah Reach" and "Response Architect" tools perform autonomous multi-channel outreach on behalf of the Business.
Data Controller Status: In the context of autonomous outreach, the Business acts as the Data Controller under the UK GDPR. VacanCV acts as the Data Processor.
Lawful Basis for Processing: The Business warrants that it has a valid lawful basis (e.g., Legitimate Interest) for contacting candidates via Sarah Reach. The Business is responsible for ensuring compliance with the Privacy and Electronic Communications Regulations (PECR) regarding automated messaging.
Indemnity: The Business agrees to indemnify VacanCV against any regulatory fines or legal actions resulting from unauthorized or non-compliant outreach conducted through the Sarah Reach tool.
3. Governance & Human-in-the-Loop (DUAA 2025)
In accordance with the Data Use and Access Act 2025 and UK GDPR Article 22, VacanCV is designed to prevent "solely automated decision-making" in the recruitment lifecycle.
Human Verification Gates: The Service requires a "Human-in-the-Loop" (HITL) rationale at critical hiring milestones (e.g., final shortlisting and offer generation). Businesses agree not to bypass these manual verification gates.
Right to Explanation: VacanCV provides a "Logic Summary" for every AI-generated scorecard. This summary is intended to fulfill the candidate's statutory right to an explanation regarding AI-assisted decisions.
Audit Trail: Every interaction between Sarah 3.1 and a candidate is logged. This audit trail is the property of the Business but may be accessed by VacanCV for compliance monitoring or as required by the Information Commissioner’s Office (ICO).
4. AI Training & Data Sovereignty
No Cross-Client Training: VacanCV warrants that it shall not utilize proprietary Business data, candidate shortlists, or private interview transcripts to train or fine-tune its core AI models for the benefit of other commercial clients. Your data remains siloed to your account.
Anonymized Metadata: VacanCV reserves the right to use anonymized, aggregated metadata (e.g., system latency, broad match accuracy rates) to improve the general technical performance of the Sarah 3.1 engine.
5. Forensic Intelligence Disclaimer
Decision Support Only: The "Forensic Intelligence" provided by Sarah 3.1 is a decision-support instrument, not a substitute for professional legal, HR, or recruitment consultancy advice. All hiring decisions and compliance with employment law remain the absolute responsibility of the User.
No Warranty on Accuracy: While the Service aims for a 98.4% match accuracy, VacanCV does not warrant that AI-generated CVs, cover letters, or competency reports are error-free. The final responsibility for the accuracy of a candidate’s profile lies with the Candidate (for seekers) and the Business (for hiring managers).
6. AI Sentiment & EQ Analysis Disclaimer
The Sarah 3.1 engine provides "EQ Analysis" and "Cultural Vibe" reporting based on tonal, linguistic, and behavioral markers. You acknowledge that these outputs are subjective and interpretive insights generated by AI. They are provided as a tool for human recruiters and must not be used as the sole basis for any employment decision. VacanCV expressly disclaims liability for any claims of bias or discrimination arising from the use of AI sentiment analysis.
7. DUAA 2025 & Human-In-The-Loop Governance
In compliance with the Data Use and Access Act 2025 (UK), VacanCV operates a "Human-In-The-Loop" architecture.
Verification Gates: No candidate assessment is final until a human user has reviewed and verified the AI-generated rationale.
Right to Explanation: Users agree to provide candidates with a "Logic Summary" upon request, using the transparency tools provided within the Service.
8. Sarah Reach & Outreach Responsibility
When using autonomous outreach tools (Sarah Reach), the Business User is solely responsible for ensuring that the targeting and contact of candidates comply with the UK GDPR and Privacy and Electronic Communications Regulations (PECR). VacanCV provides the technology but does not provide the legal basis (e.g., Legitimate Interest) for your specific outreach campaigns.
9. Data Integrity & Model Training
VacanCV respects the proprietary nature of your recruitment data. We warrant that no User Content or candidate data uploaded by you will be used to train or refine Sarah 3.1 models for the benefit of other customers. Your data remains siloed to your account.
10. Forensic Intelligence vs. Professional Advice
The term "Forensic Intelligence" refers to the depth of data analysis provided by the Service. It does not imply, and the Service does not constitute, professional legal, HR, or recruitment consultancy advice. All hiring decisions and compliance with employment law remain the absolute responsibility of the User.
11. Candidate Success Hub & Prep Lab
Coaching Disclaimer: The Prep Lab and AI Interview Coach provide coaching based on general STAR method principles. Success in a Prep Lab session does not guarantee success in a formal interview or the securing of a Sarah-Verified badge.
Verification Badges: "Sarah-Verified" badges indicate a candidate has met specific algorithmic benchmarks during a simulated assessment. They do not constitute a formal accreditation of professional skill.
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