Short answer. Do not assume that every job must be analyzed separately, or that all jobs using the same vendor can safely be pooled. Job/position grouping is a scoping and methodology question unless the rule expressly addresses a different type of “group.”
Do not confuse job groups with classification groups
6 RCNY §5-301(b)(4) expressly requires calculations for each specified group when the AEDT itself classifies candidates or employees into groups, such as leadership styles. That requirement concerns the AEDT's classification outputs. It is not a general rule prescribing how unrelated job titles must be pooled or separated.
Questions that affect job-level scoping
- Is the same AEDT version/configuration used across the positions?
- Does the output mean the same thing for each role?
- Are thresholds, ranking logic or downstream decision rules different?
- Are hiring and promotion populations mixed?
- Are different employers, agencies or deployment contexts involved?
- Would pooling hide material differences in how the tool is used?
- Would splitting create cells too small to support a meaningful analysis?
When combined analysis may require caution
Pooling records merely to increase sample size can create a misleading audit if materially different workflows, outputs or decision thresholds are combined. Conversely, splitting a genuinely consistent deployment into many tiny groups can make rates unstable and reduce interpretability.
Recommended documentation
A defensible audit record should document why the chosen population and grouping structure corresponds to the defined AEDT use case. The reasoning belongs in the audit methodology and scope record rather than being presented as a blanket DCWP rule.
Vendor audits and multiple customers
A vendor may support or commission an audit using historical data from one or more employers, subject to §5-302. That does not mean every customer deployment is automatically identical. Employers and employment agencies still need to confirm that the audit they rely on is appropriate for their covered use.
Last legally reviewed: September 27, 2026.