{"resourceId":"kentucky-personnel-memo-26-09-bars-ai-in-application-review-screening-selection-20260519","versions":[{"version":"external-99f466988d1440ef6c268716afe0377dd5076137fe5671f2cf6b84b9f3257e6e","resource":{"id":"kentucky-personnel-memo-26-09-bars-ai-in-application-review-screening-selection-20260519","title":"Kentucky Personnel Memo 26-09 bars AI from reviewing applications, screening candidates or making selection decisions in Executive Branch hiring, while allowing non-decision HR drafting uses","organization":"Kentucky Personnel Cabinet (Secretary Mary Elizabeth Bailey); Commonwealth Office of Technology","sector":"State workforce and hiring (AI use policy)","geography":"Kentucky","publishedAt":"2026-05-19","publicationDate":"2026-05-19","eventDate":"2026-05-19","sourceName":"Kentucky Personnel Cabinet","sourceLabel":"Kentucky Personnel Cabinet, Personnel Memo 26-09, 'Use of Artificial Intelligence in Human Resource Tasks', May 19, 2026","sourceUrl":"https://extranet.personnel.ky.gov/Personnel%20Memos/2026-09.pdf","evidenceClass":"standards-guidance","outcomeClass":"cautionary","topics":["governance-procurement","accessibility-workforce","data-security"],"finding":"Kentucky's Personnel Cabinet directed, effective immediately on May 19, 2026, that AI tools are not approved for reviewing applications, screening candidates or making selection decisions in Executive Branch hiring, citing potential discriminatory bias against protected classes and equal employment opportunity law. HR staff may use AI for non-decision tasks: drafting job postings and position descriptions, template letters, summarizing non-confidential data and sample interview questions, under COT policy CIO-126. Entering applicant data, PII or other sensitive records into any AI tool is prohibited, and the rules will be added to statewide hiring training. Why now: California's Oct 19 launch of applicant-side GenAI job matching makes the line between helping applicants and screening them a live design question for other states.","sledRelevance":"It is a clear, citable state control that separates permitted HR drafting uses from prohibited selection uses, a template other HR departments and CIOs can adapt as AI hiring tools spread.","evidence":"Policy text only; no incident or bias finding is cited as the trigger. Permitted and prohibited uses and the data-entry ban are stated directly in the memo.","architectureImplications":"Interpretation: HR systems and any AI features added by applicant-tracking vendors need a way to disable ranking, scoring or screening functions, and AI tools used for drafting must not be connected to applicant records.","governanceImplications":"Defines a decision boundary (no AI in review, screening or selection) and assigns compliance to all staff in the hiring process, with training updates. Agencies still need inventory and monitoring to confirm vendor features do not reintroduce screening.","securityPrivacyImplications":"Prohibits entering applicant data, PII, Social Security numbers, medical information or other sensitive records into any AI tool, regardless of tool approval status.","caveats":"Issued May 19, 2026, before this stream's recent runs; included for its relevance to the Oct 19 California launch. Enforcement method, monitoring and exceptions are not described. The memo applies to the Executive Branch.","streamIds":["state-government"],"roles":{"sales":"Sales framing: Kentucky shows that some states will rule out AI in candidate screening altogether, so hiring-tool pitches built on ranking or filtering applicants will hit a policy wall. The opening is helping HR leaders use AI safely in permitted, non-decision work, such as postings, letters and interview question drafts, and confirming their vendor tools comply. Do not position this memo as evidence that AI screening is biased; it cites potential bias as a precaution, not a finding.","engineering":"Engineering framing: compliance depends on configuration, not just policy. Engineers should inventory AI features in applicant-tracking and HR platforms, confirm scoring or screening functions can be turned off and stay off after vendor updates, and keep drafting tools separated from applicant records. Data-loss controls that block PII from reaching AI tools support the memo's ban on entering applicant data. Validation should include a test that PII cannot reach approved tools.","delivery":"Delivery framing: the Personnel Cabinet owns the rule, but agency HR teams carry it out. Delivery work is a practical playbook: list permitted uses with examples, set up approved drafting tools, add the restriction to hiring training as the memo requires, and run periodic checks that vendor features have not reintroduced screening. Track questions and exceptions so the policy can be revisited with evidence."},"roleDetails":{"sales":{"customerProblem":"HR departments want AI help but face bias and equal employment risk in hiring decisions.","stakeholders":["State personnel secretary","Agency HR administrators","State CIO and AI policy coordinator","General counsel","Hiring managers"],"discoveryQuestions":["Which HR tasks do staff already use AI for?","Do your applicant-tracking tools include AI ranking or scoring features?","How would you verify those features stay disabled?","What training covers AI in hiring today?"],"valueHypothesis":"A permitted-use playbook and vendor-feature review may let HR teams use AI for drafting while staying within a no-screening policy; no time savings are measured in this source.","potentialEngagement":"Four-week HR AI compliance review: inventory AI features in HR systems, draft a permitted-use playbook and training content, and recommend configuration controls.","unsupportedClaims":["That AI screening tools are proven biased","That the policy reduced discrimination","Any productivity gain from permitted uses"]},"engineering":{"fit":"States with central HR platforms and an AI policy office able to set configuration standards.","architectureIntegration":"Configuration review of applicant-tracking and HR suites to disable AI screening; approved drafting tools kept separate from applicant data; data-loss prevention rules for PII.","prerequisites":["Inventory of HR systems and their AI features","Approved AI tool list under state policy","Data-loss prevention capability","Training platform access"],"constraints":["Vendor updates can add AI features","Applies to Executive Branch only","State civil service and EEO law vary","Monitoring method not specified"],"security":"Block applicant PII and sensitive records from AI tools through policy and technical controls; log AI tool use in HR contexts.","proofOfValue":["Confirm screening features are disabled in each HR system","Test that PII cannot be pasted into approved AI tools","Sample HR AI use for compliance"]},"delivery":{"work":"Operationalize a no-AI-screening rule with a permitted-use playbook, configuration controls and training.","dependencies":["Personnel cabinet policy owner","State CIO AI policy","HR system vendors","Training team"],"ownership":"State personnel cabinet, with agency HR administrators accountable for compliance.","skillsAdoption":"Train HR staff and interview panels on permitted versus prohibited uses with worked examples.","governanceCheckpoints":["Annual vendor feature review","Training completion tracking","Exception and question log review","Policy refresh as tools change"],"acceptanceCriteria":["Proposed: all HR systems documented with screening features disabled","Proposed: hiring-process staff training completion tracked toward full coverage","Proposed: periodic sample finds no applicant PII in AI tools"],"risks":["Shadow AI use in screening","Vendor features enabled by default","Policy too broad to allow helpful applicant-side tools","No monitoring to detect breaches"]}},"retrievedAt":"2026-10-19T22:18:43-05:00","enrichedAt":"2026-10-19T22:22:54-05:00","enrichmentBasis":"retrieved source","accessibilityWorkforceImplications":"Protects applicants from untested automated screening; HR staff still need training on permitted uses so the rule does not suppress helpful drafting work.","procurementImplications":"HR technology contracts should let the state disable AI ranking and screening features and require notice before new AI features are enabled.","operatingModelImplications":"Decision authority in hiring stays with people; AI is confined to support tasks, which keeps accountability clear.","sourceVerification":{"openedUrl":"https://extranet.personnel.ky.gov/Personnel%20Memos/2026-09.pdf","referenceExcerpt":"AI tools and applications are not approved for reviewing applications, screening candidates, or making any selection decisions in the Executive Branch hiring process.","promptVersion":"sled-research-v4.0","model":null,"basis":"agent-reported inspection"}}}]}