DATA PROTECTION FOR HIRING

GDPR-Compliant Applicant Tracking System

Track candidate consent, set how long you keep data, remove candidate records, and export it in a few clicks, with EU customer data hosted in Germany.

4.7
4.8
based on 1,300+ reviews
100Hires GDPR settings with enable GDPR, data retention period, auto-delete, and consent requests

What a GDPR-compliant applicant tracking system should let you control

An applicant tracking system cannot make you GDPR compliant on its own. What GDPR-compliant recruitment software should do is give you the controls to track consent, set retention periods, run deletion workflows, show a privacy notice, and export candidate data.

100Hires is a GDPR-compliant data processor under Article 28, and you remain the data controller. That split matters: you decide the lawful basis, the privacy notice, and the outreach rules for candidates.

Consent is not always the right basis in recruitment, since applying for a job is not the same as consent. 100Hires records the consent you collect and applies the retention, deletion, and export workflows you configure, so the controls match the decisions you have already made.

Stop scrambling when a candidate asks you to delete their data

The most common source of GDPR exposure in recruiting is not a misconfigured system. It is the email inbox. A candidate sends their CV directly, and it sits in Outlook. Their details get forwarded to a hiring manager.

Notes from the call go into a spreadsheet. Months later they send a deletion request, and you do not know where everything is.

Right-to-be-forgotten and access requests are also arriving more deliberately. Candidates who feel ignored or treated unfairly now send data subject access requests as a form of accountability.

Erasure requests that used to be rare now arrive monthly for many EU and UK hiring teams.

Recruiters are unsure how long they can hold a CV, what a privacy notice has to say, and what to do when a candidate emails asking for everything on file.

Then procurement gets involved, asking where data is hosted, whether you sign a DPA, and what happens to the candidates you reject and the resume database you build over time.

When the answers live in scattered spreadsheets and inboxes, every one of those questions becomes a fire drill. GDPR-compliant recruitment software keeps the candidate-data controls and records in one hiring system.

Keep GDPR work inside the hiring workflow

100Hires candidate GDPR consent status and request controls

Know who consented, and when

100Hires captures candidate consent and keeps the status on every profile, so the consent status is always clear. Send a consent request in one click, and the candidate gets a page that names your company, your retention period, and a link to your privacy policy. Every consent change is kept in the audit trail.

  • Request consent in one click
  • Send retroactive consent to email applicants
  • Consent status on every candidate profile
  • Audit trail of consent changes
100Hires GDPR settings - data retention period, auto-delete, and auto-send consent renewal

Hold candidate data on a clock, then clear it on request

Set a data retention period from 1 to 60 months. When it runs out, 100Hires can auto-delete the candidate or auto-send a renewal request first. When a candidate asks to be removed, the Remove candidate profile action deletes all of their data from the record, and you can export candidate data to CSV for an access request.

  • Data retention from 1 to 60 months
  • Interview notes follow the same retention clock
  • Auto-delete when consent expires
  • Remove candidate profile for erasure
100Hires AI Copilot prompts configuration with account-level AI controls

Use AI without training models on your candidate data

100Hires does not use your candidate data to train its AI, and its AI sub-processors run under paid terms that prohibit training on your data. AI Score, AI Copilot, and the AI Email Composer can be switched off at the account level. Review your own automated rules too, such as knockout questions that can auto-disqualify candidates, since a decision made with no human in the loop can carry extra obligations under GDPR.

  • No training on your candidate data
  • AI features can be disabled at the account level
  • AI supports human decisions
  • Review rules that auto-disqualify candidates

What your security and procurement team will ask for

Security reviews ask the same questions every time. Here is how 100Hires answers them in one place, with the hosting, encryption, and DPA details your procurement team will want on file. For the full program, see the 100Hires security overview.

What they ask How 100Hires answers
Data residency EU customer data is hosted in Germany on Hetzner. Data for the US, Canada, and the rest of the world is hosted on AWS in the US.
Encryption TLS 1.2 or higher in transit, and AES-256 at rest.
DPA and SCCs A GDPR-compliant DPA including Standard Contractual Clauses is available on request at privacy@100hires.com.
Sub-processors A published list of sub-processors. Each sub-processor has a DPA with 100Hires.
Breach notification 100Hires notifies you without undue delay, within 72 hours of confirming a breach, to support your Article 33 response.
Data ownership and AI You own your candidate data. 100Hires never sells it and does not use it to train its AI.
Hosting and audits ISO 27001-certified data centers (AWS, Hetzner). SOC 2 Type II attestation is in progress, with controls already mapped to the SOC 2 criteria.

Give procurement straight answers on candidate data

Walk your security reviewers through 100Hires hosting, encryption, and DPA details, and see how candidate-data controls fit your hiring process. For your transfer terms, ask for the DPA at privacy@100hires.com.

How to choose the best ATS for GDPR compliance

Skip the vendor badges and look at the controls. The best ATS for GDPR compliance is the one that covers the specific obligations recruiting teams actually face, without an enterprise implementation project to switch them on.

  • Consent tracking - request consent in one click, see the status on every candidate profile, and keep an audit trail of changes
  • Retention with auto-delete - set how long you keep candidate data and let expired records clear themselves
  • Erasure and export - handle right-to-be-forgotten and access requests in a few clicks, not a week of inbox archaeology
  • Data residency and a DPA - know where candidate data lives (EU customer data in 100Hires is hosted in Germany) and get the DPA with SCCs procurement will ask for, available on request
  • AI without training on your data - candidate data is not used to train AI, and AI features can be disabled at the account level, with AI built to support human decisions

Run any hiring system on your shortlist through this checklist, including 100Hires: the controls and procurement answers above are documented on this page.

If you also hire in US healthcare, the same evaluation logic applies to HIPAA, and the HIPAA-ready ATS page walks through it.

100Hires vs a typical ATS on GDPR

Here is how 100Hires lines up against a typical ATS on the GDPR features hiring teams actually use, with pricing you can check up front.

100Hires
From $49 per month
Typical ATS
Varies
GDPR consent management
Often available; implementation varies
Configurable retention with auto-delete
Retention may exist; auto-delete varies
One-click erasure (right to be forgotten)
Often available; confirm scope
Bulk export for data requests
Export process varies
EU data residency
EU (Germany)
Varies by vendor and region
DPA and SCCs on request
Usually available; terms vary
No AI training on your data
AI terms vary; confirm no training on your data
Atiq Arshad
Technical Recruiter @Kidan

It solved all of my recruitment problems and offered all of the features I was looking for. It can automate most of my recruitment processes.

Source: G2
Philipp Maschelski
Talent Acquisition Partner @G42

I'd happily recommend it to my industry peers. I'm able to use the platform with ease and don't have to think twice what function to use.

Source: Capterra
Teodora Franich
HR Manager @TeachMeSkills

The system is very user-friendly. Even people with no experience will find it easy to understand its functionality.

Source: G2
Capterra Shortlist 2026 Capterra Best Ease of Use 2026 Capterra Best Value 2026 Software Advice Front Runners 2026 Software Advice Most Recommended 2026 G2 Leader Winter 2026 G2 Users Love Us 2026
4.7
4.8
based on 1,300+ reviews
72%
Less time
screening candidates
96%
Higher candidate
response rates
81%
Reduced
time to fill
53%
Lower cost
per hire
Common questions about GDPR and 100Hires
+ Is 100Hires GDPR compliant?
100Hires is a GDPR-compliant data processor under Article 28, and you remain the data controller. 100Hires gives you controls to support your obligations, including consent tracking, configurable retention, candidate deletion workflows, data export, and a DPA, while you decide your lawful basis and how you handle candidates. No tool makes your organization compliant on its own.
+ Where is my candidate data stored?
EU customer data is hosted in Germany on Hetzner, and data for the US, Canada, and the rest of the world is hosted on AWS in the US. Both paths use encryption in transit and at rest. For transfer terms, ask 100Hires for the DPA with Standard Contractual Clauses at privacy@100hires.com.
+ How does 100Hires handle candidate consent?
100Hires lets you request consent in one click, shows the current consent status on every candidate profile, and keeps an audit trail of changes. Consent is not always the right lawful basis in recruitment, and applying for a job is not the same as consent, so you choose and document your basis while 100Hires records what you collect.
+ Can a candidate ask me to delete their data?
Yes. In 100Hires, the Remove candidate profile action deletes all of that candidate's data from the candidate record, which helps you respond to an erasure request. You can also set auto-delete so candidates whose consent has expired are removed automatically.
+ How do I handle a data subject access request?
GDPR requires you to respond to a data subject access request within 30 days. In 100Hires, exporting a candidate gives you their full record in one CSV - profile fields, notes, messages, application history, and evaluations. Bulk GDPR actions let you handle requests across many candidates at once. That covers both the access and data portability obligations in a few clicks.
+ How long does 100Hires keep candidate data?
You set a retention period from 1 to 60 months in your 100Hires GDPR settings, after which consent lapses and the data can be auto-deleted. Account cancellation is a separate workflow: data is kept for 6 months for reactivation, then irreversibly deleted, including from backups, with a certificate of data destruction available on request.
+ Do you provide a DPA and SCCs?
Yes. 100Hires offers a GDPR-compliant Data Processing Agreement that includes Standard Contractual Clauses for international transfers. Request it from privacy@100hires.com so your procurement or legal team can review it before you roll out 100Hires.
+ Does 100Hires use my candidate data to train AI?
No. 100Hires does not use your candidate data to train its AI, and its AI sub-processors run under paid terms that prohibit training on your data. You can switch off AI features like AI Score, AI Copilot, and the AI Email Composer at the account level.
+ Is 100Hires SOC 2 certified?
100Hires is currently in the process of obtaining SOC 2 Type II attestation, and its controls already map to the SOC 2 Trust Services Criteria. It runs on ISO 27001-certified data centers from AWS and Hetzner. So the honest answer today is in progress rather than certified, and 100Hires can share its current controls for your security review.
+ How do I turn on GDPR in 100Hires?
Switch on GDPR in your 100Hires account under Settings, then set your retention period, consent options, and privacy policy URL. The setup steps are at https://help.100hires.com/en/article/gdpr-compliance-settings-121zgz5/.
+ Do candidates need to consent before you can store their CV?
Not necessarily. When a candidate proactively sends you their CV or applies for a role, legitimate interest is often the right lawful basis rather than consent. Consent is usually more appropriate when you add someone to a talent pool without a direct application, or want to contact them about future roles. 100Hires records the consent you collect and shows the consent status on each candidate profile, while you choose and document your lawful basis. A data protection professional or your DPO can confirm the right approach for your situation and jurisdiction.
+ What is the best ATS for GDPR compliance?
The best ATS for GDPR compliance is the one that covers the controls your obligations depend on: consent tracking, a configurable retention period with auto-delete, erasure in a few clicks, CSV export for access requests, clear data residency, and a DPA with SCCs on request. Use that checklist to evaluate vendors, including 100Hires, which supports each of these controls, hosts EU customer data in Germany, does not use your candidate data to train AI, and starts at $49 per month. No tool makes you compliant on its own, but the right controls make the work manageable.
+ Does GDPR apply to companies in the US?
It can. GDPR applies based on whose data you process, not where your company is registered, so a US company that recruits candidates living in the EU, or that has an establishment there, can be in scope, and the UK enforces its own UK GDPR with the same core rules. In 100Hires, GDPR controls are something you switch on in Settings, and consent tracking with retention limits is good candidate-data hygiene even outside the EU. Your DPO or legal counsel can confirm what applies to your situation.
23,000+ recruiters & business owners read this newsletter

The hiring playbook, in your inbox

One email a week - benchmarks, AI screening tactics, and short interview templates from the 100Hires team. No product pitches.

Put GDPR controls where your recruiters already work

Start free to switch on the GDPR controls your EU and UK hiring needs, or book a demo and walk your security reviewers through them.

We use cookies to offer you our service. By continuing to use this site, you consent to our use of cookies as described in our policy