A practical DPIA guide for hiring platforms. Review data types collected, assess risks, strengthen security controls, and ensure transparent, compliant candidate communication.

Abhishek Kaushik
Nov 19, 2025
A DPIA (Data Protection Impact Assessment) is required when a hiring platform processes personal data in ways that may affect privacy or decision fairness. Interview platforms record video, voice, transcripts, behavioral signals, and evaluation summaries. Because of this, legal and compliance teams use DPIAs to confirm that the platform handles personal data ethically and securely.
Data Protection Impact Assessment Guidance for Hiring and Interview Intelligence Software
Below is a reusable template that organizations can adapt.
It focuses on transparency, proportionality, retention control, and auditability.
1. Project Overview
Field | Description |
|---|---|
Platform Name | Insert vendor name (Example: Sherlock) |
Purpose of Processing | Conducting interviews, generating evaluation notes, verifying identity and authorship signals, improving decision consistency |
Data Subjects | Job candidates, interviewers, hiring managers |
Data Types | Video, audio, transcription, interaction metadata, interview notes, structured scorecards |
2. Lawful Basis for Processing
Select applicable basis:
Legitimate interest in fair and consistent hiring outcomes
Explicit consent from candidate at the start of the process
Contractual necessity when hiring for employment placement
[FACT] GDPR allows processing of personal data during hiring when tied to legitimate organizational interest as long as transparency is maintained.

3. Data Processing Activities
Category | Description |
|---|---|
Collection | Interview recordings, transcripts, reasoning patterns, identity verification checks |
Storage | Encrypted at rest on secure cloud servers (verify region) |
Access | Recruiters, hiring managers, platform administrators with role-based permissions |
Sharing | Optional export to ATS or HRIS systems |
Deletion | Configurable retention windows and request-based deletion tracking |
4. Risk Assessment
Risk | Likelihood | Impact | Control Measures |
|---|---|---|---|
Unintended access to recordings | Low | Medium | Role-based access, audit logs |
Excessive data retention | Medium | High | Retention policy controls and automated purges |
Candidate misunderstanding of processing | Medium | High | Clear consent and transparency notice |
5. Security & Governance Controls
Encryption in transit and at rest
SSO enforcement
SCIM provisioning for controlled identity management
Full audit logging
Data residency selection
Documented retention controls
[PROOF] Insert vendor SOC2 + ISO 27001 summary reference.

6. Candidate Transparency Statement (Insert in Candidate Communication)
We record and analyze interviews to support consistent, fair hiring decisions.
This helps ensure evaluations reflect demonstrated reasoning and actual experience.
You may request deletion of your interview data at any time as allowed by law.
[LEAD MAGNET] Download: Editable DPIA Word + Google Doc Version
SSO + SCIM Setup Guide
Identity, Provisioning, and Access Governance for Hiring Teams
Interview platforms should not operate as isolated user islands.
To control who can access interview recordings, notes, and evaluation data, organizations should integrate Single Sign-On (SSO) and SCIM provisioning.
Why SSO Matters
SSO lets users authenticate using your identity provider (IdP) such as:
Azure AD
Okta
Google Workspace
OneLogin
This ensures users enter with company-level authentication rules including MFA, session expiry, and conditional access.
Why SCIM Matters
SCIM synchronizes user accounts and roles:
When an employee joins, they are auto-provisioned
When they leave, access is revoked immediately
Group membership determines their access privileges
This prevents security drift and shadow access.
[FACT] Most data exposure incidents in HR systems stem from delayed access removal, not platform breaches.
Setup Steps
Step 1: Confirm Required Configurations
SAML or OIDC authentication support
SCIM 2.0 endpoint availability
Service provider metadata file
Step 2: Configure SSO in Your IdP
Create a new application integration
Upload platform metadata or manually enter audience + ACS URL
Map user identity fields (name, email, employee ID)
Turn on MFA enforcement
Step 3: Enable SCIM
Generate SCIM API token from platform admin console
Enter SCIM base URL and token into IdP provisioning settings
Map groups to platform roles (Recruiter, Interviewer, Admin)
Test deactivation event by offboarding a dummy user
Recommended Role Structure
Role | Access Level |
|---|---|
Admin | Configures platform + manages integrations |
Recruiter | Views interview insights, summaries, and notes |
Interviewer | Participates and reviews their own interviews |
Hiring Manager | Consumes summaries and decisions only |
Compliance and Audit Logging
Ensure the platform:
Logs every user access session
Logs every export or download
Logs permission changes
Allows exporting of logs to SIEM tools
This is required in incident response playbooks.


