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GDPR and Recruitment: A Compliance Overview for HR Teams

What GDPR actually requires from recruitment software and hiring processes — written for HR teams, not lawyers.

If you hire candidates located in the EU or UK, GDPR applies to your recruitment process — regardless of where your company is headquartered. This is a practical overview, not legal advice; consult counsel for your specific obligations.

What Counts as Recruitment Data Under GDPR

CVs, application forms, interview notes, assessment results, and even informal recruiter notes about a candidate are all personal data under GDPR. That means they're subject to the same lawful-basis, retention, and access-request rules as any other personal data your company holds.

Lawful Basis for Processing

Most recruitment processing relies on "legitimate interest" (you need the data to evaluate the candidate for a role) rather than consent, though some activities — like keeping a CV on file for future roles after a rejection — typically do require explicit consent.

Retention Limits

GDPR doesn't set a fixed retention period for candidate data, but it requires you to define one and stick to it. A common practice is 6–12 months for rejected candidates unless the candidate has separately consented to a talent pool.

Candidate Rights

Candidates can request access to the data you hold on them, ask for corrections, or request deletion. Your recruitment software needs to make it realistically possible to fulfill these requests — not just store data, but locate and export or delete it on demand.

What to Check Before Buying Software

  • Where is candidate data physically stored (EU data residency matters for some organizations)?
  • Can the vendor support a data subject access request within a reasonable timeframe?
  • Does the tool support configurable, automatic data retention/deletion policies?
  • Is there a signed Data Processing Agreement (DPA) available?

Browse HR compliance tools or check a specific country's requirements on our country pages.

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