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Using personal data

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Guest user Created:   Mar 20, 2018 Last commented:   Mar 20, 2018

Using personal data

After I interact with a candidate (interview/ phone interview/ or even if he tells me that he does not want to be contacted again) I will need to store a comment with whatever happened, how it went, what was agreed or discussed - my question is, how can I keep these comments of candidates, would it be feasible to just have his profile stored without any personal information except his name and maybe the link to his LinkedIn profile - this would be solely for professional reasons, we wouldn't want any of my colleagues or even my self to contact that person again in the future without knowing that we did it before and there might be a history?
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Andrei Hanganu Mar 20, 2018

Answer:

Even if you just store the comments and a link to a Linkedin profile you would still be holding on to personal data because the interview notes would be linked to a linkedin profile thus to a data subject.

The thing is that LinkedIn is a professional network and the purpose of the data in there is for the candidates to be known and contacted by potential employers so as long as you keep to the purpose of recruitment you are free to use the data you get from LinkedIn.

However, if you decide to use a LinkedIn profile and establish and conduct an interview you become a data controller and you need to deal with requests from the candidates. And if a candidate requests you to delete the data you need to comply with the request unless the data is:
- necessary for rights of freedom of expression or information;
- for compliance with a legal obligation under Union or Member State law;
- in the public interest or carried out by an official authority;
- for public interest in the area of public health;
- for archiving or research; or
- for legal claims.

So, unless you fit into one of the above mentioned situations you would need to delete the data including the interview notes if they can be linked to candidate.
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paulindolean Mar 20, 2018
Thank you very much Andrei, however, if it is not too much trouble, I would like to follow up with another question related to this - in case one of the candidates I interacted with, asks me to never contact them again / completely remove their details from our system - how will I be able to make sure that in the future I, or any of my other colleagues will not contact him again, as he requested, given the fact that we have to delete all the comments and information we had on him?
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Andrei Hanganu Mar 21, 2018
If you get the candidate profile from LinkedIn or another similar platform the candidate should have the option to make his/her information unavailable by blocking a certain member (https://www.linkedin.com/help/linkedin/answer/2839) you can do the same on your end. You can choose to be proactive and suggest the candidate to block you out as well since he/she have that possibility.

However, you can also inform the candidate that you need to be keeping some minimal information so that you don`t engage him again and deleting all information might mean that he/she might be contacted again if the profile is visible to all.
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