NYC Local Law 144 AI Hiring Bias Audit Checklist
Use this checklist to verify an AEDT has a current independent bias audit, a public summary, and the required candidate notice before it is used in NYC hiring. It helps you confirm Local Law 144 controls by tool, role, and workflow.
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Overview
This checklist is for reviewing an automated employment decision tool used in NYC hiring under Local Law 144. It helps you verify three things that matter most: the tool is actually in a covered hiring workflow, the independent bias audit is current and tied to the active AEDT, and the candidate notice and public summary are available in the right form.
Use it when a team is preparing to launch an AEDT, renewing a vendor, changing the model version, or documenting a periodic compliance review. It is especially useful when multiple business units use different tools or when the hiring process includes resume screening, ranking, scoring, or other automated recommendations. The checklist creates a single record for scope, audit evidence, disclosure, exceptions, and sign-off.
Do not use this template as a substitute for the bias audit itself or for legal advice. It will not tell you whether the model is fair; it tells you whether the required controls are present, current, and documented. It is also not the right tool for a hiring process that does not use an AEDT, or for a system that is outside the covered NYC workflow. If the tool version, job family, or notice language changes, rerun the checklist so the record matches the live process.
Standards & compliance context
- This template supports documentation for NYC Local Law 144 by checking the independent bias audit, public summary, and candidate notice requirements for AEDTs used in hiring.
- The audit verification section aligns with common governance expectations under ISO 9001-style document control and traceability, even though the legal driver is local employment law.
- If the AEDT affects hiring decisions in a way that implicates employment screening practices, the checklist helps create a defensible record for HR, legal, and vendor oversight.
- Public summary and notice controls should be reviewed alongside internal policy, ATS workflow settings, and any applicable state or municipal employment rules.
- Where accommodations or alternative selection processes are offered, the workflow should be reviewed with counsel to ensure the notice language and process match current legal requirements.
General regulatory context for orientation only — verify current requirements with counsel or the relevant agency before relying on this template for compliance.
What's inside this template
Audit Setup and AEDT Scope
This section matters because Local Law 144 controls depend on the exact tool, hiring stage, and business unit in scope.
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Inspection scope identifies the specific AEDT, hiring stage, and business unit covered
Document the tool name, vendor if applicable, role(s) or job family, and where the AEDT is used in the hiring process.
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AEDT use is confirmed in a covered employment decision workflow
Verify the tool is used to substantially assist or replace human decision-making in screening, ranking, or selection.
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Current policy or SOP defines ownership for Local Law 144 compliance
Confirm there is an assigned internal owner for audit tracking, notice management, and remediation follow-up.
Independent Bias Audit Verification
This section matters because the audit must be current, tied to the live AEDT, and supported by documented findings and remediation.
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Independent bias audit report is current
Verify the audit was completed by an independent auditor and is within the current required review period for the AEDT in use.
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Audit report identifies the AEDT and evaluation methodology
Confirm the report clearly names the tool, the assessment method, and the selection rate or impact analysis used.
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Audit findings and any observed disparities are documented
Check that the report includes results by protected category or other required analysis groupings and states whether disparities were found.
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Corrective actions or mitigation plan exists for any identified deficiency
If the audit identified a non-conformance or adverse impact, verify a documented remediation plan, owner, and target date are present.
Public Summary and Disclosure
This section matters because candidates and reviewers need a public summary that is accessible, current, and matched to the active tool.
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Public summary of the bias audit is available
Confirm a public-facing summary is posted or otherwise made available as required for the AEDT.
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Public summary includes the required audit date and tool identification
Verify the summary identifies the AEDT and states the date of the independent bias audit.
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Public summary is accessible without unreasonable barriers
Check that the summary is publicly accessible through a stable link or equivalent method and is not hidden behind login or request-only access.
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Public summary is current and matches the active AEDT version
Confirm the posted summary corresponds to the version of the tool currently used in hiring decisions.
Candidate Notice and Hiring Workflow Controls
This section matters because notice must reach the candidate before AEDT use and the delivery method needs proof.
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Candidate notice is provided before AEDT use
Verify candidates receive notice before the AEDT is used in the hiring process.
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Notice explains the AEDT's role in the hiring decision process
Confirm the notice states that an automated employment decision tool will be used and describes the purpose of the tool in the process.
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Notice includes instructions for requesting an alternative selection process or accommodation, if applicable
Verify the notice provides a clear contact path or process for candidates who need an accommodation or alternative review path.
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Notice delivery method is documented
Record how the notice is delivered to candidates.
Records, Exceptions, and Sign-Off
This section matters because retained evidence, exception tracking, and approval are what make the compliance record usable later.
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Supporting records are retained for the audit, summary, and notice
Confirm records are retained in a retrievable format, including audit report, public summary, candidate notice, and remediation evidence.
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Any exceptions or non-conformances are documented with owner and due date
List any deficiencies, the corrective action owner, and the target completion date.
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Inspector sign-off
Inspector confirms the review is complete and accurate.
How to use this template
- 1. Identify the exact AEDT, hiring stage, and business unit in scope so the checklist records the specific workflow being reviewed.
- 2. Attach the current independent bias audit report and confirm it names the same tool version and evaluation method used in production.
- 3. Verify the public summary is posted, accessible, and aligned to the active AEDT version and audit date.
- 4. Confirm the candidate notice is delivered before AEDT use and that the delivery method is documented in the hiring workflow.
- 5. Record any exceptions, assign an owner and due date for remediation, and complete sign-off only after the required evidence is attached.
Best practices
- Tie the checklist to one AEDT instance at a time so version changes do not blur the audit trail.
- Capture the hiring stage in plain language, such as resume screening or interview scoring, so reviewers can confirm the tool is used in a covered decision point.
- Keep the audit report, public summary, and candidate notice in the same record set to avoid mismatches between documents.
- Document the exact notice delivery method, such as ATS banner, email, or application page, rather than noting only that notice was provided.
- Flag any disparity, missing disclosure, or outdated summary as a non-conformance and assign a due date before the tool is used again.
- Review the checklist whenever the vendor updates the model, changes the scoring logic, or expands the tool to a new role family.
- Retain evidence of approval and remediation so you can show the compliance path during an internal audit or legal review.
What this template typically catches
Issues teams running this template most often surface in practice:
Common use cases
Frequently asked questions
What does this checklist cover?
This template covers the core controls needed to verify an automated employment decision tool used in NYC hiring. It walks through AEDT scope, the independent bias audit, the public summary, candidate notice, and record retention. It is meant to document whether the tool is ready for use and whether required disclosures are in place.
When should this audit checklist be used?
Use it before an AEDT is deployed in a covered hiring workflow, and again whenever the tool, vendor, job family, or decision stage changes. It is also useful during periodic compliance reviews and after a new bias audit is issued. If the public summary or candidate notice changes, the checklist should be rerun.
Who should complete the checklist?
It is usually completed by HR compliance, legal, talent acquisition operations, or a designated audit owner with input from the hiring team and vendor contact. The person signing off should be able to confirm the exact tool version, workflow, and notice process. If your organization uses a procurement or risk team, they should be included as well.
Does this template replace the independent bias audit itself?
No. This checklist verifies that the required independent bias audit exists, is current, and matches the active AEDT. It does not perform the statistical audit or generate the underlying analysis. You still need the actual audit report and any mitigation plan from the auditor or vendor.
What are the most common mistakes this checklist helps catch?
Common issues include using a public summary that does not match the live tool version, missing candidate notice language, and audit reports that are out of date. Teams also miss documenting the hiring stage where the AEDT is used or fail to retain proof that the notice was delivered. This checklist makes those gaps visible before they become a non-conformance.
How does this relate to NYC Local Law 144?
The checklist is aligned to the Local Law 144 workflow for AEDT use in NYC hiring, including the independent bias audit and notice requirements. It is designed to help teams confirm that the tool is covered, the audit is current, and the disclosure is accessible. It is not a substitute for legal review of your specific process.
Can this template be customized for different hiring stages or business units?
Yes. You can adapt the scope section for resume screening, video interview scoring, assessment ranking, or other covered decision points. Many teams clone it by business unit, job family, or vendor so each AEDT instance has its own audit trail. That makes it easier to track version changes and ownership.
How should this checklist be integrated into the hiring workflow?
It works best as a gate before the AEDT is enabled in the ATS or recruiting workflow. You can also link it to vendor onboarding, change management, and periodic compliance reviews. If your ATS supports attachments or approvals, store the audit report, public summary, and notice evidence with the checklist record.
What if the audit finds a disparity or other deficiency?
Document the finding, assign an owner, and record the corrective action or mitigation plan before the tool is used or continued in scope. Depending on the issue, that may mean changing the model, updating the workflow, narrowing use, or pausing deployment. The checklist should show the exception status clearly so the decision is traceable.
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