18  ILLINOIS BUSINESS LEADER
EMPLOYMENT LAW
to hire, discriminate 
against, or retaliate 
against a worker for 
using company-issued 
equipment to record 
a crime of violence, 
including domestic 
or sexual violence, 
against themselves or 
a family or household 
member.
	 The law also pro-
hibits employers from 
taking away com-
pany-issued devices 
because an employee 
used them to capture 
or attempt to capture 
such incidents. Additionally, em-
ployers must provide employees with 
access to any photos or recordings 
of violent crimes stored on company 
equipment.
Amendment to Childcare  
Act of 1969
In August 2025, the Illinois Childcare 
Act of 1969 was amended. House Bill 
3439 (Public Act 104-0307) updated 
the Illinois Child Care Act of 1969 
to strengthen background check 
requirements for employees and vol-
unteers. Under the new law, anyone 
working at a daycare center, daycare 
home, or group daycare home must 
complete a criminal background 
check every five years.
	
The amendment also creates a 
secure background check program 
run by the Illinois Department of 
Early Childhood. Through this 
program, daycare providers can 
hire an employee or volunteer on a 
probationary basis if the individual 
receives a qualifying result as deter-
mined by the Department.
Artificial Intelligence in Employment
Beginning in January 1, 2026, House 
Bill 3773 will amend portions of the 
Illinois Human Rights Act to pro-
hibit employers from using artificial 
intelligence (“AI”) for many employ-
ment decisions including, “recruit-
ment, hiring, promotion, renewal of 
employment, selection for training or 
apprenticeship, discharge, discipline, 
tenure, or the terms, privileges, or 
conditions of employment,” if such 
use discriminates employees on the 
basis of a protected class.
	
The statute amendment defines 
AI as a “machine-based system that, 
for explicit or implicit objectives, 
infers, from the input it receives, how 
to generate outputs such as predic-
tions, content, recommendations, or 
decisions that can influence physical 
or virtual environments.”
	
The amended statute also makes 
it a civil rights violation for failing to 
notify employees of the employer’s 
use of AI and for using zip codes as a 
proxy for protected classes. The law 
also requires employers to provide 
notice to applicants and employees 
whenever AI is used in employment 
decisions.
	
The statute does not provide 
specifics on how notice to employees 
should be given. Dykema attorneys 
will monitor for additional guidance 
from the Illinois Department of Hu-
man Rights.
	
To learn more about any of the 
Illinois state law topics above and 
how they impact your business, or 
any other general questions, please 
contact the authors of this article, or 
your Dykema relationship attorney.
House Bill 3439  
(Public Act 104-0307) 
updated the Illinois 
Child Care Act of 
1969 to strengthen 
background check 
requirements for 
employees and 
volunteers. Under 
the new law, anyone 
working at a daycare 
center, daycare home, 
or group daycare 
home must complete a 
criminal background 
check every five years.

View this content as a flipbook by clicking here.