Transparency Notice -- Artificial Intelligence

This document is a template. It must be validated before contractual commitment.

1. AI System Identification

System name: Athena -- Schedule Optimization Engine

Provider: CONSILIOWEB, SAS with a share capital of 1,000 euros, registered with the RCS Brive-la-Gaillarde under number B 892 889 858, with registered office at 13 Lestrade, 19200 Ussel.

The Athena engine is an integrated component of the Orkelis SaaS service, a team scheduling and management platform.

2. System Purpose

The Athena engine is designed to automatically generate optimized team schedules. It produces schedule proposals that simultaneously respect:

-- Legal constraints: labor law (maximum working hours, daily and weekly rest, etc.) and applicable collective agreements (CCN 51, HCR, etc.)

-- Operational constraints: position coverage, required skills, minimum staffing levels

-- Individual preferences: employee availability, shift preferences, leave requests

-- Fairness objectives: balanced distribution of shifts (weekends, nights, public holidays) among team members

3. Technical Operation

3.1. Technical approach:

The Athena engine relies on operations research techniques (constraint programming, multi-criteria optimization). It is NOT a deep learning system, neural network, or machine learning system in the traditional sense.

3.2. General operation:

-- The system models business constraints as mathematical constraints

-- It explores the solution space using constraint programming algorithms

-- It optimizes the solution according to weighted criteria (legal compliance, coverage, fairness, preferences)

-- It produces one or more candidate schedules ranked by optimization score

3.3. The system is deterministic: for the same set of constraints, it produces the same result.

4. Data Used

4.1. The Athena engine exclusively uses the following data, provided by the Client:

-- Business constraints: positions to cover, required skills, minimum and maximum staffing, rotation rules

-- Availability: available and unavailable slots, approved leave

-- Skills: qualifications and certifications (e.g., degrees, industry certifications)

-- Legal rules: labor law and applicable collective agreement parameters

-- Scheduling history: previous schedules for fairness calculation

4.2. The Athena engine does NOT use any of the following data:

-- Biometric data (fingerprints, facial recognition, etc.)

-- Health data

-- Data relating to ethnic origin, political opinions, religious beliefs, or sexual orientation

-- Browsing or geolocation data

4.3. No profiling within the meaning of Article 22 of the GDPR is performed by the system.

5. Role of Human Decision

5.1. The schedule generated by the Athena engine is a proposal submitted for human validation. The system makes no autonomous decisions directly affecting employees.

5.2. The manager or administrator retains full control over the schedule:

-- They can accept, modify, or reject the generated proposal

-- They can manually adjust any slot before publication

-- They must explicitly validate the schedule before it is communicated to employees

5.3. No schedule is published or communicated to employees without a voluntary validation action by an authorized human.

6. Risk Classification -- EU AI Act

6.1. Regulation (EU) 2024/1689 classifies AI systems by risk level. The Athena engine does NOT fall into the high-risk category (Annex III of the Regulation) for the following reasons:

-- The system is not used for recruitment, selection, or evaluation of job candidates

-- The system does not make decisions affecting working conditions, promotion, or dismissal of workers

-- The system constitutes a scheduling aid (operational scheduling), not a human resource management tool within the meaning of the Regulation

-- The final decision remains entirely under human control (human-in-the-loop)

6.2. The system falls under the "minimal risk" or "limited risk" category. CONSILIOWEB nevertheless applies the transparency obligations of Article 52 of the Regulation as best practice.

7. CONSILIOWEB Commitments

CONSILIOWEB commits to:

-- Keeping this notice up to date in the event of significant changes to the Athena engine's operation

-- Informing clients of any change in the system's technical nature (e.g., introduction of machine learning techniques)

-- Ensuring the traceability and explainability of results produced by the engine

-- Not using the system for surveillance, scoring, or discrimination of workers

-- Cooperating with competent authorities in the event of an inspection or audit relating to AI Regulation compliance

Contact

For any questions regarding the Athena engine or this notice:

CONSILIOWEB -- Email: [email protected] -- Phone: +33 6 82 87 73 19

13 Lestrade, 19200 Ussel -- SIREN: 892 889 858

Last updated: March 2026.