Warden Watch

Massachusetts: Fostering Artificial Intelligence Responsibility Act (S. 35)

MassachusettsLegislationNot in force

Massachusetts Senate Bill 35 introduces Chapter 149B to the General Laws to regulate electronic monitoring tools and automated decision systems (ADS) in employment. The bill applies to employers operating in Massachusetts, covering employees, job candidates, and independent contractors. It restricts electronic monitoring to specified legitimate business purposes and establishes strict limits on continuous tracking, biometric monitoring, and off-duty data collection. Employers using electronic monitoring or ADS tools must conduct annual independent impact assessments, provide advance written disclosures, obtain written consent for electronic monitoring, and maintain meaningful human oversight over key employment decisions like hiring, discipline, termination, and compensation. The legislation also grants workers data access rights, prohibits predictive behavior profiling, and protects workers who refuse harmful AI outputs

Impact

What this means for HR and vendors

HR and recruitment teams

HR and talent acquisition teams operating in Massachusetts must review electronic surveillance and automated decision-making systems. Deploying electronic monitoring or ADS tools requires pre-use written disclosures, candidate and employee consent for monitoring, and mandatory annual independent impact assessments. HR teams must ensure automated tools do not solely determine hiring, promotion, termination, discipline, or compensation, establishing internal human reviewers with authority and time to verify output accuracy. HR must also establish processes for data correction and handling worker non-retaliation protections.

HR technology vendors

HR technology vendors supplying electronic monitoring or ADS solutions to Massachusetts employers face significant commercial requirements. Deployers must secure access to developer documentation, training data sources, technical specifications, and historical version records to conduct independent impact assessments. Vendors must support data minimization, facilitate prompt disposal of non-essential employee data, comply with deletion requests, and ensure tools avoid prohibited capabilities such as unapproved facial recognition, gait, voice analysis, or emotion recognition.

Key obligations

What organizations need to do

Practical obligation briefings focused on what the requirement is, who it applies to, when it applies and what teams should consider doing.

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