Owner: General Counsel
Co-signers: CTO
Effective Date: May 10, 2026
Reviewed: Annually
This template provides the start-of-conversation disclosure required when a Neuroscale AI agent (or a Customer-deployed AI agent operating on the Arbi platform) initiates or sustains a conversation with a Candidate. Applicable disclosure obligations include:
  • California Bus. & Prof. Code §17941 (SB 1001 — Bot Disclosure) — disclosure when an automated bot conducts a conversation with a person in California with the intent of incentivizing a purchase or sale of goods or services. Recruiting outreach falls within the disclosure trigger.
  • EU AI Act Art. 50(1) — AI-system-interaction disclosure for any AI system intended to interact with natural persons, unless it is obvious from context.
  • Utah AI Policy Act §13-72-201 — disclosure for generative AI used in interactions that may influence the recipient.
  • State-by-state analogues — Texas TRAIGA chatbot disclosure provisions; Massachusetts and New Jersey advisory guidance.
The disclosure must appear at the start of every AI-agent-initiated conversation, not only at onboarding, and must be repeated when the channel changes (e.g., from email to SMS).

Templates

Email (initial outreach)

Subject: {{personalized_subject}}

Hi {{candidate_first_name}},

I'm an AI assistant working with {{customer}}'s recruiting team, operating on
the Arbi recruiting platform by NEUROSCALE LLC. I'm reaching out about the
{{job_title}} role at {{customer}}.

{{personalized_message_body}}

You can talk with a human at {{customer_recruiting_team}} anytime by
replying with "human" or by emailing {{customer_recruiter_email}}. If you'd
prefer not to receive further messages, reply "stop" and I will end this
sequence. To request removal from Neuroscale's broader candidate database,
email privacy@neuroscale.ai with the subject "Sourcing Database — Removal."

{{ai_agent_signature}}

SMS (initial outreach)

Hi {{candidate_first_name}} — I'm an AI assistant from {{customer}}'s
recruiting team about the {{job_title}} role. Reply HUMAN to talk to a
recruiter, STOP to end. Msg & data rates may apply. — Arbi, by NEUROSCALE LLC
Subsequent SMS messages within the same conversation thread (within 30 days) need not repeat the disclosure, but every message must honor STOP / UNSUBSCRIBE / QUIT keywords immediately.

Voice (automated / pre-recorded)

“Hi, this is an automated AI assistant calling on behalf of {{customer}}‘s recruiting team, using the Arbi recruiting platform by Neuroscale. I’m reaching out about the {{job_title}} role. If you’d like to speak with a human recruiter, press 1 or stay on the line. To opt out of future calls, press 9 or say “stop.” This call may be recorded for quality assurance.”

In-app or web chatbot (Candidate-facing)

Persistent banner at the top of the chat surface and a first-message disclosure:
🤖 You are chatting with an AI assistant (Arbi, by NEUROSCALE LLC, on behalf of {{customer}}). Type “human” at any time to be transferred to a recruiter at {{customer_recruiting_team}}. Your conversation may be reviewed by {{customer_recruiting_team}} and is retained per {{customer_privacy_notice_url}}.

Channel switch (e.g., email → SMS)

When the conversation moves to a new channel:
“Hi {{candidate_first_name}} — just letting you know, this is still the AI assistant from {{customer}}‘s recruiting team (Arbi, by Neuroscale). We’re moving to SMS for faster scheduling. Reply STOP anytime.”

Required elements (checklist)

Each disclosure must include, at minimum:
  • Identity of the system as AI (not human). “AI assistant,” “automated assistant,” or equivalent.
  • Operator identity — Neuroscale and the Customer-employer on whose behalf the outreach is made.
  • Purpose — recruiting outreach about a specific role.
  • Path to a human — reply keyword, email, phone, or equivalent.
  • Path to opt out — STOP / UNSUBSCRIBE / removal; SMS opt-out honored within 60 seconds.
  • Privacy notice link — Customer’s privacy notice and/or Neuroscale’s Privacy Notice.

Honoring opt-outs

  • SMS: Reply STOP, QUIT, UNSUBSCRIBE, END, CANCEL — auto-acknowledged within 60 seconds; no further messages.
  • Email: Functioning unsubscribe link in every email; honored within 10 business days per CAN-SPAM and within 24 hours operationally.
  • Voice: Press 9 / “stop”; no further automated calls; entry on internal Do-Not-Call list.
  • Global Neuroscale suppression list: privacy@neuroscale.ai with subject “Global Outreach Suppression” — suppresses across all Customers.
  • Sourcing Database removal: Distinct from outreach opt-out — see Art. 14 Indirect Collection Notice §10.

Variables

VariableDescription
{{personalized_subject}}Personalized email subject line
{{candidate_first_name}}Candidate’s first name
{{customer}}Customer-employer on whose behalf the outreach is made
{{job_title}}Title of the role the outreach concerns
{{personalized_message_body}}Personalized message body
{{customer_recruiting_team}}Name/label of the Customer’s recruiting team
{{customer_recruiter_email}}Email address of the Customer’s recruiter
{{ai_agent_signature}}AI agent signature (e.g., “Arbi — on behalf of the Customer”)
{{customer_privacy_notice_url}}URL of the Customer’s privacy notice

Cross-references

Version history

VersionDateDescriptionAuthorApproved by
1.0May 10, 2026Initial templateCameron WolfeIshan Jadhwani