Treat open licensing as limited and assess the company’s: Which conclusion is most defensible?

Open licensing does not erase duties triggered by a qualifying employment-screening use and the company’s role.

The question

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1. Employment screening is outside high-risk rules because the model is general-purpose.

   High-risk analysis follows intended purpose and use; a general-purpose model can support a high-risk downstream application.
2. Treat open licensing as limited and assess the company’s high-risk duties separately. ✓

   The facts combine an open license with a qualifying employment use, so licensing cannot displace separate application and role-based duties.
3. The model provider alone bears every screening responsibility.

   Responsibilities depend on roles and conduct; the company’s purpose-setting and deployment can create duties independent of provider obligations.
4. Open licensing alone determines that no high-risk duties apply.

   Open licensing does not determine application risk classification or erase duties arising from the company’s employment-screening purpose.

How to remember it

Open licensing does not erase duties triggered by a qualifying employment-screening use and the company’s role.

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