A practical framework for managing candidate data correctly under KVKK: privacy notices, retention periods, access control, and deletion processes.
Candidate data is personal data; some of it (health, criminal records) is special-category personal data. The employer is the data controller, and the purpose, retention period, sharing conditions, and deletion processes of the data must be clearly defined.
A privacy notice should be shown during the application process; for some processes (such as keeping candidates in a pool), explicit consent must be obtained. If audio recording and transcription are used in the AI interview process, this must be clearly stated in the notice.
Data of candidates who don't fit the position should be deleted or anonymized after a set period. For data kept in the candidate pool, renewed-consent processes should be established and automatic deletion jobs defined.
Who accesses candidate data is a crucial question. Role-based access, team- and position-based visibility, and an audit trail for critical actions are mandatory. Candit.ai provides these controls within the product.
For third-party processors such as the AI interview service, voice call infrastructure, and transcript providers, a data processing agreement should be signed, and data location and cross-border transfer conditions should be checked.
Candidates must always be able to exercise their rights to access, rectification, deletion, objection, and data portability. A flow that collects and tracks these requests (a form or a KVKK channel) is mandatory.
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