Warden Watch

Pennsylvania: Automated Employment Decision Tool Transparency and Audit Bill (HB 594)

PennsylvaniaLegislationNot in force

Pennsylvania House Bill 594 amends the Pennsylvania Human Relations Act to regulate the use of automated employment decision tools (AEDTs) in hiring and employment practices across the Commonwealth. The legislation applies to employers and employment agencies that deploy statistical or machine learning systems to automatically filter job candidates or assist in making decisions regarding hiring, promotions, compensation, or other terms of employment. It establishes mandatory pre-interview transparency rules, requiring employers to notify individuals at least ten days before an interview, explain how the tool works, and obtain explicit candidate consent prior to evaluation. Additionally, the bill prohibits deploying an AEDT unless it has undergone an independent bias audit for disparate impact within the previous year and a summary of the audit results is published on the deployer's public website.

Impact

What this means for HR and vendors

HR and recruitment teams

HR and recruitment teams operating in Pennsylvania must implement strict disclosure, consent, and audit workflows before deploying automated decision tools. Processes must ensure candidates receive written notice and system explanations at least ten days prior to interviews, and that candidates who withhold consent are excluded from automated evaluation. HR teams must also confirm that any active AEDT has undergone an independent bias audit within the past 12 months and that the audit summary is published on the organization's public website.

HR technology vendors

HR technology providers supplying AEDTs to Pennsylvania employers face commercial expectations to support deployers in meeting statutory audit and disclosure obligations. Vendors will need to provide deployers with plain-language explanations of model functionality and characteristic evaluations to enable compliant candidate notices. Furthermore, providers must ensure their tools undergo independent bias testing or supply deployers with the system access, data, and documentation required to perform annual bias audits.

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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