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RECRUITING AND GDPR

No software makes you compliant. This is the part it can do.

Your company decides the purpose, the lawful basis and the retention period. An applicant tracking system turns those decisions into something the hiring team follows every day, instead of a policy nobody reopens. Join is built for the second half of that sentence.

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Chronological candidate history with messages, interviews, notes and scorecards in Join

THE OBJECTION

A compliance badge on a pricing page proves nothing.

Every vendor in this category claims General Data Protection Regulation (GDPR) compliance, and the claim is close to meaningless on its own: the regulation binds your company as controller, not the tool. Article 28 of the GDPR puts the processor on documented instructions from you. So the useful question is narrower than "are you compliant" — it is which of your decisions the software can actually enforce, and which ones it quietly leaves to somebody remembering.

  • You choose the lawful basis, the retention period and the privacy notice
  • The tool applies them to every candidate record without a calendar reminder

THE ANSWER

Six things to make a vendor demonstrate

Ask for the contract, the access model, and what happens the day a retention period expires or an erasure request lands.

CriterionWhat to insist onHow Join answers it
Contract and accountability
Processing agreementAn Article 28 contract covering instructions, audit rights and end of servicePublic data processing agreement, part of the service
Sub-processorsA current list with purpose, location and safeguards for transfersList and supporting documents published in the Trust Center
Day-to-day operation
AccessPermissions per role and per hire, never one shared loginCompany roles plus roles granted job by job
RetentionA configurable period the system applies to the whole recordDeletion or anonymisation when the period you set runs out
Candidate rightsAccess, rectification and erasure from the record itself, not a support ticketJSON and PDF export, redaction and full deletion on the profile
ConsentWording, date, purpose and withdrawal all evidencedStatus and trail held against the candidate profile
Granting access job by job in Join to limit which applications a person can open

RETENTION

There is no EU-wide number for keeping a rejected CV.

This is where most policies stall, because people look for a figure the regulation never supplies. Retention follows from purpose and from the window in which a claim can still be brought, and both are member-state questions. France's CNIL, for instance, accepts a two-year pool measured from the last contact, provided the candidate was told and can object; Germany arrives at roughly six months by adding two statutory deadlines together — two months to assert a discrimination claim in writing under § 15(4) AGG, three to file it under § 61b ArbGG, plus buffer. Pick the period your counsel can defend, write it into the privacy notice, then make the system apply it.

  • The period covers the whole record: CV, messages, notes, scorecards, attachments
  • Anonymisation keeps the hiring metrics and drops the identity
  • Keeping a CV for future roles is a new purpose, and usually needs consent

THE EVIDENCE

Documents you can read before you buy

No certification replaces your own vendor review. These are the artefacts Join publishes so security, legal and hiring can check them independently.

BUYING QUESTIONS

What to settle before you sign

What are the technical requirements for a GDPR-compliant applicant tracking system?
At minimum: an Article 28 processing agreement, permissions by role rather than a shared login, a configurable retention period the system enforces on the full record, a consent trail where a second purpose applies, tooling to answer access and erasure requests without a support ticket, and published documentation on hosting, sub-processors and transfers. A compliance statement on a website evidences none of those. Ask for the artefact behind each one.
How long can we keep a rejected candidate's CV?
The regulation gives no single figure, and the honest answer is that it depends on your member state and on the purpose you can name. France's CNIL works to two years from the last contact for a talent pool, with the candidate informed and able to object. German practice lands near six months, because § 15(4) AGG gives a rejected candidate two months to assert a discrimination claim in writing and § 61b ArbGG gives three more to file it. Whatever you choose, record the reasoning, publish the period, and let the system enforce it.
Is running hiring out of a shared inbox a GDPR breach?
Email is not unlawful in itself. The exposure comes from copies: the same CV ends up in a shared mailbox, in a forwarded attachment, in a manager's downloads folder and on a shared drive. When an erasure request arrives you have one month under Article 12(3) to find all of them. An applicant tracking system collapses that to a single record and makes access, history and deletion auditable in one place.
Where does Join host candidate data?
The platform's primary infrastructure runs on Google Cloud in Belgium, and transactional email goes through AWS SES in Frankfurt. Other providers may handle specific functions; their locations and safeguards are published in the Trust Center. That is why we describe it as primary EU hosting rather than claiming no record ever touches a service outside the EEA.
Which obligations stay with us?
Deciding why you process candidate data, on what basis, what you collect and for how long. Answering access and erasure requests also stays with you, because the duty falls on the controller. Join acts as processor for the hiring workspace under the data processing agreement, and has to give you what you need to answer — Article 15(3) requires a copy in a commonly used electronic format, which is why export is a button rather than a request to us.
Can we try it before committing?
Yes. Start with a 14-day free trial of the Advanced plan. Up to 5 active jobs included. No charge until you decide to continue. After that, Standard is €20 per active job per month on monthly billing. Current figures are on the pricing page.

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