CHRO/HRD asks: Why Empatyzer can't be used for annual reviews and what safeguards are in place

TL;DR:

  • No individual raw data or raw scores — they cannot be used for performance settlements.
  • Empatyzer is built to improve communication and support real-time conversations, not to measure productivity.
  • Functional limits: data is aggregated at team/department level, user visibility is controlled, and individual reports cannot be exported.
  • Contractual rules, DPA/DPIA provisions, strict admin controls and audit logs add legal and operational protection for privacy and misuse prevention.

How does Empatyzer separate employee development from evaluation?

Empatyzer separates development from evaluation: the user receives knowledge about himself and regular learning, and the value of the product lies in better performance, not in the ranking of employees.

Features that can help:

  • Traits: Shows features by strengths and possible costs depending on the situation, rather than turning the profile into a human assessment.
  • Micro-lessons: They are used to develop the user's skills over time and consolidate knowledge, not to compare people in a rating system.

Empatyzer was not designed for annual performance reviews and does not provide per-person raw results that could be used for formal evaluation or settlements. The product focuses on enhancing communication, self-awareness and supporting conversations in the moment rather than measuring productivity or effectiveness. Built-in functional limits include no export of individual diagnoses, aggregation of metrics at team or department level, and configurable visibility so profiles and responses stay private. Provider access is tightly controlled and logged, customer data is stored separately on EU servers, and contractual terms explicitly prohibit using Empatyzer outputs for employee assessments. Data-processing agreements and DPIA notes define processing bases and retention; the tool does not train models on client data and conversation content is not shared with HR or managers beyond the product. From a technical side, encryption, environment separation and the option for rapid account and data deletion on request further protect privacy. Participation is voluntary, privacy settings let users hide profiles, and the product can only offer communication guidance to help prepare for reviews — it cannot replace formal metrics or HR decisions. Integrations with HR systems or SSO are not required, reducing the risk of linking Empatyzer data to payroll or HRIS. If someone attempts to misuse information contrary to the agreement, access can be audited and violations traced so the company can invoke internal procedures. This mix of functional blocks, contractual provisions and technical safeguards minimizes the risk of Empatyzer being used as a tool for annual reviews.

Summary: Empatyzer supports development and communication, but its functional limits, contractual clauses and privacy protections mean it should not be used for annual performance reviews.

Sources and research

  1. European Parliament & Council of the European Union. (2016). Regulation (EU) 2016/679 (General Data Protection Regulation). Official Journal of the European Union, L 119, 1–88. Source
  2. European Data Protection Board. (2020). Guidelines 4/2019 on Article 25 Data Protection by Design and by Default (Version 2.0). Source
  3. American Educational Research Association, American Psychological Association, & National Council on Measurement in Education. (2014). Standards for Educational and Psychological Testing. American Educational Research Association. Source
  4. Qadri, U. A., & Moustafa, A. M. A. (2026). AI-enabled HRM as an ethical system: a systematic review of fairness, accountability, governance and legitimacy. International Journal of Ethics and Systems. Advance online publication. https://doi.org/10.1108/IJOES-04-2026-0308 DOI: 10.1108/IJOES-04-2026-0308

Author: Empatyzer

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