Govern · jurisdiction
United States
NYC Local Law 144 requires an independent bias audit for automated employment decision tools used on New York City candidates. That audit has not been commissioned.
Units governed
553
Stamped on the unit itself
Placements here
15
961,222 records
Inbound routes
4
Records arriving from elsewhere
Outbound routes
1
Records leaving this jurisdiction
Breach notice
720 hr
Supervisor: California Privacy Protection Agency; FTC for unfair practice
The regime that applies here
Privacy and artificial intelligence obligations, as they stand.
Privacy regime
State patchwork
CCPA/CPRA (California), plus twelve further state statutes in scope
Artificial intelligence regime
Sectoral and state
Partly in force — Some provisions apply now, the rest phase in on a published timetable.
Transfer adequacy
Framework participation
Default mechanism: EU-US Data Privacy Framework certification
Supervisory authority
California Privacy Protection Agency; FTC for unfair practice
Local obligations that change how work is run
These are operating constraints, not footnotes.
Localization rule
No federal residency requirement. Health and biometric data attract state-specific handling.
Employee consultation
No works council duty. Illinois BIPA and NYC Local Law 144 bite on hiring tools.
What is stored and processed here
One row per class of record, per role, per system.
| Record class | Role | System | Facility | Volume | Note |
|---|---|---|---|---|---|
| agent-telemetry | Stored | This platform platform-core | AWS us-east-1, Northern Virginia | 1,772 | |
| agent-telemetry | Processed | This platform platform-core | AWS us-east-1, Northern Virginia | 8,054 | The platform control plane reads every record from the US region. |
| candidate-applications | Stored | Recruiting and Applicant Tracking ats | Vendor cloud, Oregon | 51,432 | |
| candidate-applications | Processed | Recruiting and Applicant Tracking ats | Vendor cloud, Oregon | 51,432 | |
| compensation | Processed | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 19,170 | |
| compensation | Stored | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 19,170 | |
| customer-contact | Stored | Customer Relationship Management crm | Vendor cloud, Washington | 339,112 | |
| employee-master | Processed | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 19,170 | |
| employee-master | Stored | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 19,170 | |
| health-safety | Stored | Occupational health record store ehs | Vendor cloud, Ohio | 1,254 | No agent access. |
| performance-records | Stored | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 20,033 | |
| performance-records | Processed | Core HR and Payroll hcm | Workday US pod, Portland Oregon | 20,033 | |
| research-payloads | Stored | Research Notebook and Experiment Data eln | On-premise, Cambridge Massachusetts | 5,997 | Asserted from the site register. No feed. |
| supplier-bank | Stored | Group ERP — Financials erp-fi | AWS us-east-1, Northern Virginia | 13,063 | |
| support-transcripts | Processed | Contact Center Platform ccaas | Vendor cloud, Oregon | 372,360 |
Inbound — records arriving here
Lawful basis and impact assessment state for each route.
XFER-007DE→USCleared
Marketing automation and campaign attribution on the global instance.
Adequacy decisionEU-US Data Privacy Framework, recipient self-certified, verified 2026-02-19Assessment current128,000/mo
XFER-008DE→USCleared
Platform control plane reads evidence records from every region to serve the cockpit.
Standard contractual clausesIntra-group agreement, EU SCC Module 1, executed 2025-04-08Assessment current1,520/mo
XFER-009DE→USCleared with conditions
Model inference. Prompt and completion content leaves the region for the model provider.
Standard contractual clausesModel provider DPA with EU SCC Module 2, executed 2025-09-22Assessment current412,000/mo
Zero-retention is contracted, and the platform cannot independently verify it. Verification depends on the provider attestation, which is the same weakness the evidence chain has without external anchoring.
XFER-013DE→USUnresolved
Joint research program between the Ludwigshafen and Cambridge sites.
No personal dataNot personal data. Export control screening under EAR and EU dual-use.Not required0/mo
The laboratory notebook has no feed, so the platform cannot see whether this transfer happens or at what volume. It is on the register because the site register says the program exists, not because the platform observed it.
Outbound — records leaving here
Lawful basis and impact assessment state for each route.
XFER-014US→SGCleared
Candidate screening for US requisitions at the Singapore hub.
Explicit consentCandidate notice and consent captured at application, US flow onlyNot required4,260/mo
Which functions run work here
Rolled up from the jurisdiction stamped on individual units.
AI GBS & Global Business Services44
Engineering44
Finance44
Procurement & Source-to-Pay44
Revenue Operations43
Marketing41
Supply Chain40
Legal40
Human Resources39
Information Technology38
Customer Service37
Research & Development36
Sales32
Administration31