Why HR Is Paying Attention

Digital coaching appeals to organisations for three main reasons:

1.    It enables personalised learning at scale. Unlike traditional training programmes, digital coaches can adapt to individual learning styles and progress, offering targeted resources and short learning interventions that suit busy working lives. This flexibility can be helpful for organisations with dispersed teams.

2.    These tools provide consistency and accessibility. Employees can access guidance at any time, reducing reliance on scheduled training sessions and creating a more continuous learning experience.

3.    When used appropriately, digital coaching platforms can offer useful insight for workforce planning. Aggregated data can highlight common skills gaps and development needs, helping HR teams make informed investment decisions without monitoring individuals.

Where the Risks Sit
The use of digital coaches also brings clear responsibilities for employers.

From a data protection perspective, these tools process personal data, often at a detailed level. Employers must ensure GDPR compliance, identify a lawful basis for processing and complete a Data Protection Impact Assessment where required. A Fundamental Rights Impact Assessment may also be required prior to the deployment of a “high risk” AI system. 

Where AI outputs may influence promotion, performance management or other decisions which directly impact the employment relationship, employees should be notified of the use of AI systems for such purposes.  Crucially, such decisions should only be made by a human (who is appropriately AI literate) and should be reasoned and aligned with the relevant organisational policies.

Confidentiality is another concern. Employees may share sensitive information with digital coaching tools and therefore, employees should be given advance information in relation to the processing of their data (and specifically in relation  to the use of AI systems) and the purpose for which such data will be used Contracts with providers of digital coaching platforms should clearly address data ownership, retention periods, security standards and restrictions on secondary use of data.

There is also the issue of fairness and equality. AI systems can reflect bias present in their training data. Employers remain legally responsible for ensuring that workplace tools do not discriminate employees with protected characteristics under Irish equality legislation. Ongoing monitoring and human intervention are essential.

The Role of Line Managers and Human Judgment
Learning and development does not happen in isolation. Trust, context and interpersonal relationships play a critical role in how employees experience feedback and support.

If digital coaching replaces regular conversations with line managers, organisations risk weakening engagement and trust. Line managers remain essential for interpreting feedback, understanding individual circumstances and linking development to team and organisational objectives.

The most effective approach is a blended one, where digital coaching informs and supports human-led discussions rather than replacing them.

What the EU AI Act Means for HR
The EU AI Act, which came into effect in August 2024, applies directly in Ireland and introduces a risk-based framework for AI use.

AI systems used in employment contexts, including those that influence learning, performance or career progression, are expected to fall within the high-risk category once the Act is fully applicable from August 2026 (the implementation date may be fast tracked by the Irish government).

Key obligations for employers using high-risk AI systems include:

• Informing affected employees, and where relevant worker representatives, that such systems are in use
• Carrying out the appropriate impact assessments as required by the GDPR and the EU AI Act prior to deployment of the digital coach
• Assigning meaningful human oversight to appropriately trained individuals
• Ensuring input data is relevant and representative where the employer controls it
• Providing clear explanations where AI-supported decisions have legal or similarly significant effects
• Developing and implementing an AI policy which sets out clear objectives and guidelines on the use of AI systems within the organisation.

For HR teams, the practical takeaway is clear: governance, transparency and oversight must be built in from the start.

Key Takeaways for HR Teams

• Treat digital coaching as both a learning tool and a regulated workplace system
• Be open with employees about how AI is used and what data it processes
• Ensure the digital systems are not a substitution for regular performance interactions between line managers and their direct reports.
• Regularly review AI outputs for accuracy, fairness and consistency
• Invest in AI literacy across HR and management roles

Digital coaches can add genuine value to learning and development when used well. They offer flexibility, personalisation and insight that traditional approaches often struggle to deliver.

However, technology alone does not create effective learning. For employers, success lies in combining innovation with legal compliance, human judgment and strong working relationships.