365Talents
365Talents is an AI skills-intelligence and internal talent-marketplace platform that infers employees' skills from HRIS records, CVs, documents and collaboration tools, then matches them to internal jobs, projects, gigs, mentors, learning and succession pipelines.
HireAIScore rates 365Talents 46 out of 100 (grade F, Substantial gaps) under rubric v1.0, last reviewed September 25, 2026. 365Talents ranks 39 of 86 vendors rated in Candidate sourcing AI, against a category average of 46. That score is drawn from 38 evidence items across 7 rubric criteria for 365Talents — 31 with a cited source, 7 recording that nothing was located.
§ 01 - Company facts
- Founded
- 2015
- Headquarters
- France · FR
- Pricing tier
- Enterprise
- Market side
- Employer-side (AEDT)
- Categories
- SourcingAssessment
- Website
- 365talents.com
These are company details, not findings. They are editable by a verified representative and carry no weight in the score, which is built only from the cited evidence below.
§ 02 - Score breakdown
§ Score breakdown
Category scoring
Weighted contribution shown to the right of each bar.
- 01
Article 11 Technical Documentation
Weight 20%63
+12.6 · category avg 48
- 02
Bias Audit Transparency
Weight 18%18
+3.2 · category avg 40
- 03
FRIA Support
Weight 15%35
+5.3 · category avg 31
- 04
Data Governance Disclosure
Weight 15%58
+8.7 · category avg 53
- 05
Human Oversight Design
Weight 12%57
+6.8 · category avg 56
- 06
Post-Market Monitoring
Weight 12%44
+5.3 · category avg 40
- 07
Customer Documentation
Weight 8%57
+4.6 · category avg 57
Category avg is the mean raw score on that criterion across the 86 Candidate sourcing AI vendors in scope of this rubric, this one included.
§ 03 - Strongest · weakest
Strongest category
Article 11 Technical Documentation
Raw score 63 · contributes 12.6 to total.
63 against a 48 category average
Weakest category
Bias Audit Transparency
Raw score 18 · contributes 3.2 to total.
18 against a 40 category average
§ 04 - Cited evidence
Download diligence record→§ Evidence
Cited per category
Every score is backed by at least one cited piece of evidence.
Evidence ledger
- Items
- 38
- Documentation
- 21
- Audit report
- 3
- Public statement
- 7
- Absence
- 7
- With a source URL
- 31 of 38
- Source hostnames
- 6
- Fewest items
- 4
- Bias Audit Transparency
These figures measure how thoroughly 365Talents was reviewed, not how 365Talents performed — an absence row, recording that nothing was located, is counted like any other item.
Article 11 Technical Documentation
6 items63
- AbsenceCaptured Sep 25, 2026
No public model or system card, technical documentation pack, instructions for use, accuracy metrics or explainability statement for the matching, succession or skills-inference models was found. Places searched: 365talents.com (keyword scan of its 882-URL sitemap), the trust center, the dev.to tech blog and Docebo's 365Talents pages.
- Audit reportCaptured Sep 25, 2026
The trust center publicly shows an ISO/IEC 42001:2023 certificate from Certi-Trust (ICTS France), no. CT-SMIA-022025-0CU01622. It was certified on 10 Feb 2025, is valid to 9 Feb 2028 subject to annual surveillance audits, and covers the AI management system for the 365Talents Talent Management Platform.
- DocumentationCaptured Sep 25, 2026
The same resource list names an 'AI Impact Assessment Report as per ISO42001', two AI fact sheets and an ISO 42001 surveillance audit report, but all four require an access request.
- DocumentationCaptured Sep 25, 2026
The June 2026 Prism launch post gives a short statement of what the agent is and is not: a conversational tool for an employee's next move, 'not ... a replacement for HR', and dependent on data quality. It also says 'LLM Extraction V2' uses large language models to pull skills from profiles, documents and collaboration tools.
https://365talents.com/en/resources/introducing-prism-ai-matching-agent/
- Public statementCaptured Sep 25, 2026
The European Commission lists 365Talents among AI Pact pledge signatories, whose core commitments are an AI governance strategy, mapping of likely high-risk systems, and AI literacy.
- DocumentationCaptured Sep 25, 2026
An April 2026 ethics article cites ISO 42001, SOC 2, GDPR and the EU AI Act and says AI decision-making is 'systematically documented' for traceability, but it links to no such documentation beyond the trust center.
https://365talents.com/en/resources/ethical-ai-transparency-hr-tech-365talents/
Bias Audit Transparency
4 items18
- AbsenceCaptured Sep 25, 2026
No NYC LL 144 bias audit, independent fairness audit or published impact-ratio analysis was found for any 365Talents feature. None of the trust center's 26 listed documents is a bias audit, trust.warden-ai.com/365talents returns 404, and neither 365talents.com nor Docebo's 365Talents pages mention an audit.
- Public statementCaptured Sep 25, 2026
The succession-planning page says the platform 'ensures every decision is fair and objective, eliminating bias from the succession planning process'. Its AI uses performance metrics, skills assessments and career aspirations to identify future leaders, and the page cites no testing.
https://365talents.com/en/lp/succession-planning-365talents-ai/
- Public statementCaptured Sep 25, 2026
The performance-review page claims 'Our AI evaluates employees based on their skills mastery and role requirements—no bias, no guesswork' without any published bias testing.
https://365talents.com/en/lp/performance-reviews-365talents-ai/
- Public statementCaptured Sep 25, 2026
The AI Everywhere page describes Smart Matching as 'no bias, just data-driven decisions', with no supporting audit or methodology.
FRIA Support
4 items35
- DocumentationCaptured Sep 25, 2026
The trust center lists a Privacy Impact Assessment (EN and FR), a record of processing activities and an ISO 42001 AI Impact Assessment Report. A deployer could use these for a DPIA or FRIA, but all are gated behind 'Request access'.
- DocumentationCaptured Sep 25, 2026
The ethics article says employment AI is high-risk and that a vendor's provider compliance 'does not automatically satisfy yours as a deployer', but it gives no deployer checklist, FRIA method or template.
https://365talents.com/en/resources/ethical-ai-transparency-hr-tech-365talents/
- Public statementCaptured Sep 25, 2026
The AI compliance page answers 'Yes' to whether 365Talents is EU AI Act compliant and claims alignment with 'all risk categories and disclosure requirements', but publishes no deployer materials.
https://365talents.com/en/use-case-ai-compliance-and-security/
- AbsenceCaptured Sep 25, 2026
No Article 27 fundamental rights impact assessment template, Article 26 deployer instructions or worker-information template was found on 365talents.com, the trust center or Docebo's 365Talents pages.
Data Governance Disclosure
6 items58
- Audit reportCaptured Sep 25, 2026
A public SOC 2 Type 2 letter of attestation from Prescient Assurance, dated 30 July 2025, gives an unqualified opinion on Security, Confidentiality and Availability for 17 March to 17 June 2025; the full report is gated.
- DocumentationCaptured Sep 25, 2026
The subprocessor list names only Microsoft Azure (hosting, EU), Mailjet (mass mailing, France) and Kombo (integration aggregation, EU).
- DocumentationCaptured Sep 25, 2026
The security page says customer data is hosted in France and segregated by customer. It says personal data is 'systematically validated by the employee', consent is collected at first login and erasure rights are respected.
- DocumentationCaptured Sep 25, 2026
A 2023 announcement, updated in February 2025, names Microsoft Azure OpenAI Service as the engine behind 365Talents' generative-AI features.
https://365talents.com/en/resources/microsoft-generative-ai-integration-announcement/
- DocumentationCaptured Sep 25, 2026
The Prism launch post says managers and HR cannot see agent conversations and the AI is not trained on them. It also says skills are extracted from profiles, documents and collaboration tools.
https://365talents.com/en/resources/introducing-prism-ai-matching-agent/
- AbsenceCaptured Sep 25, 2026
None of the following was found: a list of attributes or proxies excluded from matching, a description of the data used to build the matching and skills models, a retention schedule for AI inputs, or a public DPA. The PIA and record of processing are gated.
Human Oversight Design
7 items57
- DocumentationCaptured Sep 25, 2026
The Prism matching agent is described as giving every recommendation 'a clear rationale' so employees 'see exactly why a role was suggested based on their skills, experience, and stated aspirations'.
https://365talents.com/en/resources/introducing-prism-ai-matching-agent/
- DocumentationCaptured Sep 25, 2026
The internal-mobility page says the matching engine 'Explains every match so employees and managers understand the why' and respects the customer's classification rules and mobility policies.
- DocumentationCaptured Sep 25, 2026
The how-it-works page describes 'Human-in-the-Loop Validation', in which customer teams validate and refine AI-generated skills data.
- Public statementCaptured Sep 25, 2026
Docebo's internal-mobility FAQ is asked whether the product replaces manager decision-making and answers 'No. Managers stay in control', framing it as decision support.
- Public statementCaptured Sep 25, 2026
The succession page tells buyers to 'Let data lead the way'. Its AI surfaces future leaders from performance metrics, skills assessments and aspirations, and the page describes no review, override or appeal step.
https://365talents.com/en/lp/succession-planning-365talents-ai/
- DocumentationCaptured Sep 25, 2026
An April 2026 post promotes an HR-controlled, HRIS-based mode with 'Zero employee dependency' ('No logins, no self-assessments'). In that mode skills and potential successors are inferred without the employee validation the security page describes.
https://365talents.com/en/resources/skills-mapping-without-employee-input-ai/
- AbsenceCaptured Sep 25, 2026
No public documentation shows how override controls, audit logs of recommendations, per-jurisdiction settings or the advertised 'User Consent & Opt-In Controls' work; the product knowledge base at kb.365talents.com is login-gated.
Post-Market Monitoring
5 items44
- DocumentationCaptured Sep 25, 2026
An Instatus status page tracks a single '365Talents' component with email, Slack, Teams, webhook and RSS subscriptions. Its history lists no incidents and one notice: a 36-minute scheduled database upgrade on 20 August 2026.
- DocumentationCaptured Sep 25, 2026
The Vanta trust center shows live status for about 50 SOC 2-style security controls, including intrusion detection, log management and vulnerability monitoring, updated minutes before viewing.
- DocumentationCaptured Sep 25, 2026
The trust center FAQ tells anyone who detects a potential security issue to contact trust@365talents.com.
- Audit reportCaptured Sep 25, 2026
The ISO 42001 certificate requires annual surveillance audits. The trust center lists a gated 'ISO42001 Surveillance 1 Audit report' and gated disaster-recovery exercise reports from 2023 to 2025.
- AbsenceCaptured Sep 25, 2026
No AI incident channel, model-update changelog, fairness or drift dashboard, or security.txt was found. The /.well-known/security.txt path redirects to the homepage, and 365talents.statuspage.io does not exist.
Customer Documentation
6 items57
- DocumentationCaptured Sep 25, 2026
Public product pages cover the talent marketplace, internal mobility, career development, succession, performance reviews and AI agents, alongside a resource hub of articles, ebooks and webinars.
- DocumentationCaptured Sep 25, 2026
An AI compliance page summarises ISO 42001, GDPR, EU AI Act 'readiness', explainability and opt-in controls, and offers security and compliance briefings on request.
https://365talents.com/en/use-case-ai-compliance-and-security/
- DocumentationCaptured Sep 25, 2026
The trust center publicly shows the SOC 2 letter, ISO 42001 certificate and accessibility documents. The PIA, AI fact sheets, penetration test summary and security assurance plan need an access request.
- DocumentationCaptured Sep 25, 2026
The product knowledge base redirects to an email-gated login, so user and admin documentation is not publicly readable.
- DocumentationCaptured Sep 25, 2026
A post-acquisition FAQ confirms 365Talents remains a standalone product led by its founding team, with customer data staying in Europe.
https://365talents.com/en/lp/365talents-acquisition-reassuring-our-customers/
- AbsenceCaptured Sep 25, 2026
No public DPA or platform terms were found: the published privacy policy and general conditions of use cover the website and contain no AI or automated-decision terms. No NYC LL 144, Illinois, Colorado or EU AI Act deployer guidance was found either.
§ 05 - Editorial notes
Company overview
365Talents is a Lyon-based skills-intelligence and internal talent-marketplace vendor, launched at the end of 2015 by Loïc Michel, Mathieu Martin and Paul Mougel. Its platform uses LLM-based extraction to infer employees' skills from HRIS records, CVs, documents and collaboration tools. It then recommends internal jobs, projects, gigs, mentors, learning and succession candidates, and its generative features were announced on Microsoft Azure OpenAI Service. Docebo bought the company for about US$54.6 million on 20 January 2026 and still sells it standalone under its own brand, with the founding team in charge. 365Talents says more than 2 million employees in 60+ countries use it, and its customers include Société Générale, Alstom, Veolia and TotalEnergies.
Regulatory exposure
The platform ranks employees for internal moves and succession. By 365Talents' own description it also 'evaluates employees' in performance reviews, which puts it in EU AI Act Annex III point 4(b). As a French provider it faces those high-risk obligations from 2 December 2027, after the Digital AI Omnibus deferral, and the CNIL is its home GDPR regulator. An ISO 42001 certificate and an AI Pact pledge are good foundations. But the company answers a flat 'Yes' to EU AI Act compliance without publishing technical documentation or deployer guidance, and no published testing backs its 'bias-free' claims for succession and performance evaluation. US exposure is smaller but growing under Docebo. NYC LL 144 covers promotion decisions and requires an independent bias audit, which 365Talents has not published. Illinois HB 3773 has required notice of AI use in employment decisions since 1 January 2026, California's FEHA automated-decision rules have applied since 1 October 2025, and Colorado's SB 26-189 disclosure regime starts on 1 January 2027.
Path to a higher score
The biggest gain would come from an independent bias audit of the matching and succession engines, with impact ratios by sex and race/ethnicity published as an LL 144-style summary. That would either back the 'bias-free' claims or show they need to be withdrawn. Next steps: ungate the AI fact sheets and a summary of the ISO 42001 AI impact assessment. Publish a system card and instructions for use that cover intended purpose, input data (including the HRIS-only and collaboration-tool modes), excluded attributes and known limits. Add deployer guidance with an Article 27 FRIA template, employee-notice wording and a public DPA. An AI incident channel and a model-release changelog would raise the post-market monitoring score.
§ Regulatory frame
What applies to candidate sourcing ai.
Ranking outputs are inside Annex III §4 when they influence hiring decisions. GDPR Article 22 (automated decision-making) and the GDPR rights around profiling apply independently for EU candidates.
§ Compare
Build any comparison→365Talents against its nearest-scoring peers.
In Candidate sourcing AI.
§ Others rated in Candidate sourcing AI
All sourcing vendors→Ranked 39 of 86 by weighted total under rubric v1.0. The ordering is arithmetic on the rubric and carries no view on which tool suits a given hiring process.
- 36Covey47F
- 37Teamtailor47F
- 38Gloat47F
- 39365TalentsThis profile46F
- 40Brainner46F
- 41RippleMatch46F
Conflicts of interest
No vendor pays for placement, scoring, or removal. Casework - the consulting firm that operates this directory - provides paid services to some vendors. Any active or recent (within 24 months) commercial relationship is disclosed on the affected vendor profile and the review is reassigned to an independent reviewer. See the full policy on About.
Casework has no commercial relationship with this vendor.