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AI That Decides About People

Before your AI decides about a person, you will know whether it may do so and on what terms.

You will know whether your system can be used and with what safeguards.

§ 1

Approach

An AI that decides about people should only go live once it is known to respect their rights, and that check is made before launch.

First, what is prohibited

We will check that the system does not fall into any of the practices the Regulation prohibits. If it does, we will tell you before you invest any further in it.

Then, how it can operate

We will study the conditions under which it can be used: human oversight, information for the people affected and for the workforce, and the contract with your provider.

The assessments, when they are due

If the system can go ahead and the law requires impact assessments, we will quote for them separately, on a system that is already defined.

§ 2

Engagement

Firms deciding with AI
You will know whether your system can be used and with what safeguards.
€5,000 + VAT
4 weeks

El importe exacto se cierra en la hoja de encargo antes de pagar, con los gastos previsibles incluidos. Si el encargo se alarga, no pagas más.

§ 3

Process

How the engagement unfolds

Pre-Consultation NDA

A unilateral confidentiality agreement signed by PASSAS before the video consultation, available at no additional cost on request. It binds the firm alone — no signature is required from the client — and adds an explicit contractual layer on top of the professional secrecy obligations inherent to the practice of law.

Initial Consultation

A 60-minute working session by video call in which we analyse your situation, your specific needs and our ability to help you. We assess whether we can take on the matter and give you the fixed price in advance. You can book it directly through the Google Calendar link on our website and pay €90 by Stripe.

AI Regulatory Memorandum

Legal analysis of the artificial intelligence systems the company operates or deploys under Regulation (EU) 2024/1689. Determines the company's regulatory role (provider, deployer or both), classifies each system according to the AI Act risk tiers and establishes the map of applicable obligations. The documentary basis on which any compliance process is built.

Compliance Memorandum

Legal analysis of the business model that determines which rules affect the company, what legal risks exist and what documentation is mandatory before operating. Covers the sectoral regulatory framework, data protection obligations, essential contracts and any applicable authorisation or licensing requirements.

Human Oversight Protocol

A procedure establishing who reviews the AI system's decisions about people, with what information, within what time frame and with what power to correct them, in line with the GDPR and the AI Act.

Workforce Information

A document explaining to employee representatives, in plain terms, the parameters and rules of the algorithm that affects the workforce, as Spanish employment law requires.

Service Pack

Contractual documentation to formalise relationships with clients and suppliers, with the terms, liabilities and scope clearly defined from the first engagement. Includes the services agreement adapted to the company's operations, with limitation of liability clauses and payment terms, ready to sign.

Case Monitoring

Ongoing attention to the matter between the main steps: deadline control, procedural or administrative follow-up, response to requests for correction and management of court notifications. The client hears from us each time there is a development in the file, and never has to ask in order to know what is happening.

§ 4

Team

Who handles it

Guillermo Passas Varo, founding partner of PASSAS

I see legal practice as a discipline of precision. I work where the law meets technology and cross-border operations, and I read code and contracts with the same attention. Before accepting an engagement I tell you whether it is worth pursuing and what it costs, at a fixed price.

David Sánchez Lorenzo, of counsel at PASSAS

I work where economic law meets technology: litigation, contracts and artificial intelligence systems. I am drawn to the ground where the rules are still being written, and I have brought that same rigour to litigation since my first year in practice.

§ 5

Questions

What people ask before instructing this service

Which systems does this service cover?

Those that score, select or screen out people: CV screening, creditworthiness assessment, insurance pricing or decisions about the workforce.

Can you guarantee that I will be able to use my system?

We cannot guarantee it. The engagement begins by checking that the system does not involve prohibited practices. If it does, we will tell you. If it does not, we will study the safeguards under which it can be used.

Does it include the FRIA and the GDPR impact assessment?

They are quoted separately when the study concludes that the system can go ahead and the law requires them, because their scope depends on the system once it is defined. We carry them out together so that they are consistent.

When does the high-risk regime apply?

From 2 December 2027 for Annex III systems, following the Digital Omnibus. The GDPR and Spanish employment law already impose obligations today on anyone using AI to make decisions about people.

How much does it cost and how long does it take?

From €5,000 + VAT, within four weeks. The exact figure is fixed in the engagement letter before you pay.

Book your Virtual Consultation today.

Sixty minutes on Google Meet with a qualified lawyer. It costs €90 including VAT and will be deducted from the first invoice if an engagement follows.

Book a Virtual Consultation (€90)Tell us about your matter first

If you book, you will choose your lawyer and a time in Google Calendar. If you would rather tell us about your matter first, we will reply within 24 working hours.