Using AI on Internal Complaints and HR Issues (Carefully)

Internal complaints and HR investigations are some of the most sensitive work any organisation does. They involve:

allegations about colleagues and managers;
sometimes distressing or intimate facts; and
high stakes for everyone involved.

It is tempting to think that AI could help by:

summarising long statements;
extracting timelines; or
drafting investigation reports.

Used incautiously, though, AI can increase risk by mishandling nuance, amplifying bias or storing sensitive data in the wrong place.

This article looks at how AI might assist HR and management teams with internal complaints and HR issues — carefully — and where you should draw firm boundaries.

1. Be clear who is in charge: humans, not tools

Internal complaints often touch on:

discrimination, harassment or bullying;
performance management disputes;
whistleblowing and regulatory issues.

These are areas where:

judgment and empathy are crucial;
process fairness is scrutinised;
outcomes may be challenged later in tribunals or other forums.

AI should therefore be treated as, at most, a note‑taking or summarisation helper, never as:

an investigator;
a decision‑maker; or
a proxy for legal or HR advice.

Make this explicit in your policies and training so that nobody is tempted to ask a tool “what should we do about this complaint?”.

2. Set strict data and tooling boundaries

The data in HR complaints files is often:

highly sensitive personal data (health, sexuality, beliefs);
information about alleged misconduct or criminal behaviour;
details about non‑parties who have not consented to its use.

Sensible boundaries include:

no use of consumer AI tools for complaint‑specific material;
using only approved systems where data stays in a tightly governed environment;
minimising what is sent to AI even within those systems (for example, summaries rather than raw chat logs).

Where your case management or HR system offers AI features, work with IT and legal to ensure that:

prompts and outputs are encrypted and access‑controlled;
logs are retained in line with your HR and legal retention policies;
any model training or aggregation uses strictly controlled, anonymised data if at all.

3. Safe uses: structuring and organising information

Within good boundaries, there are some realistic, lower‑risk uses of AI, for example:

turning rough interview notes (taken by a human) into structured attendance notes with headings and action points;
extracting neutral timelines from dated records (“on [date], X emailed Y about…”);
preparing simple lists of issues raised for investigators to consider.

In each case:

the underlying facts come from human interviews and documents;
AI helps with presentation and organisation, not substance;
investigators and HR professionals check and amend outputs before they go on file.

Think of this as AI acting like a diligent PA, not as a junior HR adviser.

4. Clear red lines: what AI should not do in HR complaints

There are some uses you should almost certainly prohibit, such as:

assessing credibility (“does this statement sound truthful?”);
predicting outcomes (“is this likely to be upheld?”);
suggesting sanctions or remedies;
rewriting allegations in a way that changes tone or seriousness.

These tasks are laden with bias and fairness risks. They belong firmly with trained HR, legal and management professionals.

Even for drafting support, caution is needed. For example, asking AI to:

“soften” a letter upholding a complaint; or
“make this dismissal letter more robust”

— may introduce language that is insensitive or inconsistent with your policies. Anything that communicates outcomes or reasons should be drafted and owned by humans, with only light formatting help at most.

5. Confidentiality, access control and secrecy

Internal complaints can involve people who still work together day to day. AI use must respect:

who is allowed to know what;
which managers or HR staff have access to which files;
the need to avoid accidental disclosure of sensitive material.

That means:

ensuring any AI features are only available to those who already have access to the underlying complaint file;
avoiding cross‑matter or cross‑department datasets that might leak information between investigations;
keeping a tight rein on who can configure and monitor AI use within HR systems.

Case management for HR (or a specialist area in your wider system) should enforce these boundaries at a technical level, not just rely on good intentions.

6. Working with external advisers

In many serious complaints, external employment or regulatory lawyers will be involved. AI use should align with their expectations and advice.

Practical steps include:

agreeing with advisers what role, if any, AI will play in organising documents or drafting;
ensuring that any AI use is properly documented on the file;
being able to explain, if needed in litigation, how you avoided bias and preserved confidentiality.

Externals may also have their own panel or regulator‑driven requirements. Build these into your AI and HR policies rather than treating them as one‑off exceptions.

7. Documentation and future scrutiny

Internal complaints may be reviewed months or years later by:

tribunals;
regulators; or
internal audit and risk functions.

To prepare for that, make sure your systems can show:

where and how AI was used (for example, “interview notes structured, summary drafted”);
who reviewed and approved AI‑assisted outputs;
what decisions were taken by humans, based on which evidence.

This is one reason why using AI inside a governed platform like case management, rather than through ad hoc tools, is so important.

Where OrdoLux fits

OrdoLux is being designed primarily for client matters, but the same principles apply to any sensitive investigation work:

AI features focus on structuring, summarising and organising information inside secure matters;
usage is logged at matter level, supporting audit and oversight;
firms can define practice‑specific red lines and permissions so that AI is only available in appropriate parts of the system.

For internal complaints and HR issues, that means you can, in principle, use the same controlled, auditable AI workflows that you rely on in litigation and regulatory matters — while keeping careful human control over the judgments that really matter.

This article is general information for practitioners — not legal advice, employment law advice or HR guidance for any particular complaint or investigation.

Looking for legal case management software?

OrdoLux is legal case management software for UK solicitors, designed to make matter management, documents, time recording and AI assistance feel like one joined‑up system. Learn more on the OrdoLux website.