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Processing Special Category Data

It’s very well reported that, according to research, the average recruiter or hiring manager reads a candidate CV for about six seconds.  Probably about one second longer than it’s taken you to read to the end of this sentence (if you’ve read it back timing yourself, thanks for your commitment to accuracy).

We can all agree that’s not much time for a candidate to make an impactful first impression.  There’s also an argument that’s plenty of time.  The recruitment industry globally generated nearly £350 billion in 2016.  Six well spent seconds.

Six seconds is the average.  Those we don’t like are quickly discarded.  Those that could be a placement are given enough time to properly consider them.

With GDPR enforcement not far out, is six seconds enough?

Accountability for the lawful processing of personal data is what it’s all about.  Be transparent, be fair, be accountable and use data only for as long as you need to.  Simple stuff.

The challenge all recruiters face is the lack of control over some of the data that’s being pushed into the business on a candidate CV.  This sort of thing:

  • Race;
  • Ethnic origin;
  • Politics;
  • Religion;
  • Trade union membership;
  • Health or;
  • Sexual orientation

When looking down the list, how many of these have you seen on a CV?  More than once?

The above are some of the ten special categories of data specified under GDPR.  There are ten specific legal bases for processing special categories of data too, which you can find on the ICO website.

This article doesn’t seek to tell you which legal basis, if any, will work for you, rather ask two questions:

  • Do you look for any of the above in the six seconds, on average, you’ll read a CV?
  • Do you need to know this stuff while considering a candidate?

As with everything, there will of course be cases where it is very relevant, however, that’s unlikely to be the norm.

Whether you find a candidate, or they find you, if the CV has special category data in it, you must have an appropriate legal basis for processing it.  Even if you don’t want it.

This responsibility lies right the way through the candidate supply chain – job boards, aggregators, your CRM, your clients.  If this data is processed, and if it moves through the chain, the same requirement applies to each act of processing.

If processing special category data doesn’t form a necessary part of your recruitment business here’s a few suggestions to consider:

  • Include in your Fair Processing Notice that you don’t want CVs with special category data.  List the types of data you don’t want.  Be specific.
  • Speak to your CV service providers and understand what their policy is on special category data, what they’re doing and see how that aligns to your own strategy.
  • Think about how you can communicate with prospective candidates to make it clear you don’t need those types of data at point of CV receipt (include in job ads perhaps?).
  • Delete CVs that contain special category data unless you absolutely need it.
  • Train your consultants to know what you want, what to look for and what to do if they find it.

The last one will have an impact.  Six seconds could become eight seconds, or ten on average.

Will you take the extra time?


Phil Schofield, Managing Director

Obsequio Software

0333 939 8477