DCWP guidance explains that the 'in the city' analysis can include positions located at a NYC office and certain remote positions associated with a NYC office. Candidate residence is separately relevant to notice obligations. A remote workflow should therefore be scoped using job/office nexus, AEDT function and actual hiring or promotion use.
Do not use candidate residence as the only scope test
The statute defines an employment decision as screening candidates for employment or employees for promotion within the city. DCWP's FAQ adds practical location guidance. A candidate living in NYC is important for notice, but residence alone should not be substituted for the full covered-use analysis.
Remote-work scope questions
| Question | Why it matters |
|---|---|
| Which office is the role associated with? | DCWP guidance uses office/location nexus in its scope explanation. |
| Is the tool screening for a specific job or promotion? | LL144 applies to employment decisions, not generic analytics. |
| Does the tool meet the AEDT definition? | Remote work does not expand the AEDT definition. |
| Where does the candidate reside? | NYC residence is expressly relevant to notice obligations. |
Frequently asked questions
No. DCWP guidance indicates that certain remote positions associated with a NYC office can be within the location analysis.
No. NYC residence is expressly relevant to notice, but the overall scope analysis also asks whether there is covered AEDT use for an employment decision in the city.
Job/office association can be material, so employers using one AEDT across multiple locations should map the actual workflow rather than assume one answer applies everywhere.
Next step
Use this page for general information only. For a specific workflow, review the LL144 scope framework or request an independent bias-audit scope review.