Annex III assessment summary: assignment suggestions ​
Status: Template — to be reviewed by the controller's DPO / counsel. Draft of 2026-10-13; not reviewed yet.
This page summarises the existing legal assessment input and the design record ADR-0014. It adds no new legal conclusions. The assessment is the authoritative document; counsel's sign-off is recorded there (§9).
Summary ​
| Question | Working position in the assessment | Assessment section |
|---|---|---|
| Is assignment an AI system (Art. 3(1))? | Treated as an AI system (path-similarity inference and weight learning); counsel to confirm | §3.1, Q1 |
| Annex III point 4(b)? | Allocating tasks in work relationships is in scope; "based on individual behaviour" is uncertain, likely yes, because commit, blame and review history are records of past work | §3.2, Q2 |
| Art. 6(3) derogation? | Unlikely to be available, mainly because per-path familiarity may be profiling (Art. 4(4) GDPR), which excludes the derogation | §3.3, Q3, Q4 |
| Application date | Annex III high-risk obligations apply from 2 December 2027 (Regulation (EU) 2026/1744) | §3.4 |
| Roles | Quavon UG (haftungsbeschränkt) provider; customer deployer | §3.5, roles.md |
| GDPR | DPIA likely required; legal basis Art. 6(1)(b)/(f) with a balancing test | §4, dpia-assignment.md |
| BetrVG | Co-determination under § 87(1) No. 6 very likely, in every mode | §5, works-agreement annex |
Product state ​
- Assignment stays in shadow until counsel and, for German tenants, the works council sign off. Without a recorded instance legal sign-off, nothing is written to the Git host.
- The decision table (assessment §7) defines which modes are acceptable for each classification outcome. The product enforces the outcome and permitted modes recorded in
assignment_legal_sign_offs. - High-risk readiness work done so far: closed input allowlist, logging of applied assignments, explanation facts, human-oversight controls, retention, instructions-for-use wording (assessment §1).
Open ​
Counsel questions Q1–Q14 in the assessment §8. Nothing in this pack answers them.