Trust is not a promise. It is an architectural decision.
SwarmMind is designed for a minimal- or low-risk intended purpose under the EU AI Act: supporting human-led learning, reflection and collective sense-making — not making decisions about people.
Quick summary (2 minutes)
Intunex's current assessment: SwarmMind's intended purpose is a minimal- or low-risk use of AI.
- No automated employment or HR decisions.
- No employee ranking or performance scoring.
- No behavioural prediction for recruitment, promotion, dismissal or task allocation.
- Personal reflection is private by default.
- Learning information remains visible and user-controlled.
- AI supports reflection; humans remain responsible for decisions.
SwarmMind supports learning, reflection and growth. It does not evaluate, score, predict or classify people for employment or other consequential decisions.
Intended purpose and risk assessment
Intunex assesses SwarmMind's current intended purpose against the EU AI Act and the product's actual functionality.
SwarmMind is designed to:
- support user-initiated reflection and learning
- help teams build shared understanding from deliberately shared contributions
- provide suggestions that remain subject to human judgement
- keep learning information visible to the user
SwarmMind is not designed or offered to:
- make recruitment, promotion, dismissal, compensation or task-allocation decisions
- rank employees or predict individual work performance
- infer hidden motivation, loyalty or employability
- make decisions that determine a person's rights, obligations or access to essential services
On this basis, Intunex's current assessment is that SwarmMind's intended purpose does not fall within the high-risk employment and worker-management uses listed in Annex III of the EU AI Act.
Learning support is not employee scoring
SwarmMind may support user-initiated learning and skill reflection, including self-assessment or learning-oriented feedback.
These functions are designed to help the user understand and develop their own learning. They are not employee rankings, performance-management scores or automated recommendations for employment decisions. Proposed learning information remains visible to the user and is not silently repurposed for hidden HR evaluation.
Human oversight
AI-generated outputs are suggestions, summaries and learning support. People remain responsible for interpretation and decisions.
SwarmMind does not autonomously execute consequential actions about a person. Optional agentic functions are off by default and require a separate, customer-specific activation and agreement.
Responsibilities under the EU AI Act
Intunex Oy / SwarmMind acts as the AI system provider. The customer organisation acts as the system deployer.
Customer organisations are responsible for using SwarmMind within the agreed learning and reflection purpose.
We provide customers with clear documentation to support their own EU AI Act deployer assessment.
Reassessment
The assessment is reviewed when the intended purpose, material functionality or customer use changes. A request to use SwarmMind for employee ranking, automated HR decisions or another materially different purpose is not treated as ordinary configuration; it requires a new product, legal and risk decision by Intunex.