Qualified legal review required
This startup template does not provide legal advice. Qualified counsel must adapt it to the NHIP legal entity, product behavior, subprocessors, contracts, and each launch jurisdiction before publication or use.
Scope and responsible entity
[Insert NHIP legal entity name], located at [insert registered address], provides the NHIP Hiring Network. Contact the privacy team at [insert privacy email].
This policy covers NHIP websites, public job pages, candidate accounts, agency workspaces, support, and billing. An agency may control candidate data that it imports or receives. NHIP may process that data for the agency under a contract and Data Processing Addendum. Counsel must map the controller and processor roles for each product flow.
Data we may collect
- Account and identity data: name, email, phone, login identifiers, account role, organization membership, and verification records.
- Agency data: agency details, team settings, clients, contacts, jobs, notes, tasks, interviews, submissions, offers, placements, and audit records.
- Candidate data: contact details, resume files, employment, education, skills, preferences, work authorization, screening responses, applications, and visibility choices.
- Communication and file data: recruiter email activity, support messages, interview feedback, documents, and file metadata.
- Service and billing data: device and request data, security events, usage records, subscription status, and payment identifiers supplied by the payment provider. NHIP should not store full payment card numbers.
Sources of data
We may receive data from you, an agency user, a candidate, an authorized file or feed import, a public-sector job source, or a service provider acting for NHIP. User-directed URL imports should fetch the supplied job page and preserve its source.
An agency must have authority to upload candidate records and job data. A candidate who applies to an agency role sends application data to that agency. NHIP should identify the recipient before the candidate applies.
Purposes and legal bases
NHIP may process data to:
- provide accounts, public jobs, applications, and agency workflows;
- parse files, calculate match evidence, run authorized search, and prevent duplicate records;
- send requested service messages, protect accounts, enforce limits, and record audit events;
- process subscriptions, answer support requests, and meet legal duties.
Counsel must insert the legal bases that apply in each jurisdiction, including contract, consent, legal obligation, and legitimate interests where available. [Insert jurisdiction and balancing-test references].
Resume processing and matching
NHIP may extract text from a resume and use an AI provider to structure that text. The service validates structured output and stores operational metadata such as provider, model, parser version, and review status. NHIP should preserve the original resume and ask for confirmation before replacing recruiter-reviewed fields.
Application code calculates match results from stated components and weights. A result may include evidence, missing information, conflicts, sources, and confidence. NHIP will not reject a candidate based on the match result alone. The service must not infer protected traits for matching or talent search.
International transfers
NHIP may process data in countries outside the person's home country. Counsel must identify hosting regions, provider locations, and the transfer tools used for each route. These may include an adequacy decision, approved contractual clauses, or another lawful safeguard.
[Insert transfer mechanism, addendum links, and contact route].
Retention and deletion
NHIP should retain data for the period needed to provide the service, meet agency instructions, resolve disputes, enforce agreements, and satisfy law. The product should support candidate export and deletion, organization deletion, soft deletion, and configurable agency retention.
[Insert retention periods by record type, backup window, and legal hold process].
Security
NHIP uses organization-scoped authorization, row-level database rules, secure resume storage, signed file access, input and file validation, rate limits, audit logs, and secret management. No security program can remove all risk.
[Insert approved security controls, certification status, and incident contact].
Privacy choices and rights
Depending on location, a person may request access, correction, export, deletion, restriction, or objection. A person may also withdraw consent and complain to a regulator. NHIP may need to verify identity and route an agency-controlled request to the responsible agency.
Send requests to [insert privacy request address or portal]. Counsel must add response periods, appeal rights, and regulator details for each launch market.
Children, changes, and contact
NHIP targets professional recruitment and should not accept accounts from children under [insert minimum age by jurisdiction]. Contact [insert child-safety contact] if a child may have supplied personal data.
NHIP should post material policy changes with a new effective date and provide any notice that law or contract requires. Questions may be sent to [insert privacy email and postal address].