Owner: General Counsel
Co-signers: CTO
Effective Date: May 10, 2026
Reviewed: Annually
Co-signers: CTO
Effective Date: May 10, 2026
Reviewed: Annually
Purpose and legal basis
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.
Templates
Email (initial outreach)
SMS (initial outreach)
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.aiwith subject “Global Outreach Suppression” — suppresses across all Customers. - Sourcing Database removal: Distinct from outreach opt-out — see Art. 14 Indirect Collection Notice §10.
Variables
| Variable | Description |
|---|---|
{{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
- Outbound Communications Policy — TCPA / CAN-SPAM / CASL / PECR rules.
- AI Acceptable Use Policy — operator-side AI labeling and transparency.
- Terms of Service §8.8 — Customer / Neuroscale outbound-communications allocation.
- Privacy Notice — overall data handling.
Version history
| Version | Date | Description | Author | Approved by |
|---|---|---|---|---|
| 1.0 | May 10, 2026 | Initial template | Cameron Wolfe | Ishan Jadhwani |