Privacy policy for recruitment using Teamtailor
This Privacy Policy describes how Critical TechWorks collects, uses, stores and protects personal data in the context of recruitment activities.
It applies to all personal data processed through our recruitment platform (powered by Teamtailor), including applications, interviews and AI-assisted recruitment tools.
We process, manage, use and protect personal data in accordance with Regulation (EU) 2016/679 (GDPR), Portuguese Law 58/2019, Regulation (EU) 2024/1689 (EU AI Act) and this Privacy Policy. This policy contributes to CTW’s commitment to transparency, data protection and responsible use of technology in recruitment.
Target audience
This policy applies to all individuals (“Candidates”, “Users”) whose personal data is processed through CTW’s recruitment Service, including: applicants to job vacancies; individuals who register on the CTW careers portal; individuals referred by CTW employees or other candidates; and candidates submitted by external recruiters or recruitment agencies. It also applies to CTW employees involved in recruitment activities (recruiters, hiring teams, interviewers), to the extent that this policy sets out obligations for them.
Privacy Policy statement
CTW is the controller for personal data processed through the recruitment Service. The following principles govern all recruitment data processing activities, in accordance with GDPR, the EU AI Act and CTW’s Internal Privacy Policies:
Lawfulness, fairness and transparency: Personal data is processed lawfully, fairly and in a transparent manner. Candidates are informed about what data is collected, why, and how it is used.
Purpose limitation and data minimisation: Data is collected for specified, explicit and legitimate recruitment purposes. Only data that is relevant and proportionate to the recruitment process is collected and processed.
Storage limitation and integrity: Data is kept only for as long as necessary for the recruitment purpose or as required by law. Technical and organisational measures are in place to ensure data accuracy, confidentiality and integrity.
Human oversight of AI: AI systems used in recruitment operate as decision-support tools only. No candidate is automatically rejected, ranked, scored or selected without meaningful human review.
Accountability: CTW is responsible for and able to demonstrate compliance with data protection principles. Data Protection Impact Assessments (DPIAs) are carried out where processing activities are likely to result in a high risk to individuals’ rights and freedoms.
1. Purposes of Processing
The specific purposes of processing are:
To receive, process and analyse applications to specific job vacancies.
To evaluate candidates during the recruitment process, including through interviews and assessments.
To contact candidates regarding future job opportunities that may fit their profile, during the applicable data retention period.
To enable registration and use of the “Connect” reserved area and its functionalities.
To send notifications regarding opportunities and recruitment vacancies to registered Users.
To receive, analyse and store referral data provided by CTW employees or other candidates who made a referral, until the first contact with the referred candidate.
To internally process applications and assess whether a candidate (including referred candidates) fits active job vacancies.
To process and analyse applications submitted by external recruiters or recruitment agencies.
To support interview documentation, including AI-assisted transcription and structured notetaking, where applicable (see Section 7).
2. Collection of Personal Data
2.1 When and how we collect personal data
We collect personal data when Users:
Where existing CTW employees make referrals of potential candidates, personal data about such individuals will be collected. The referred individual is considered a User under this Privacy Policy and will be informed about the processing.
2.2 Categories of personal data
Personal data falls into different categories, each illustrated below with examples.
Professional data: CV, work experience, education, qualifications, certifications.
Only data that is relevant and proportionate to the recruitment process is collected and processed.
2.3 Data we do not collect
We do not knowingly collect special categories of personal data (Art. 9 GDPR) such as data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation. If such data is voluntarily provided by the User (e.g., in a CV or during an interview), it will not be used in recruitment decisions.
3. Lawfulness of processing
We process personal data on the following legal bases:
AI-assisted recruitment support tools (screening, structuring, prioritisation): Legitimate interest of CTW in efficient, consistent, and fair recruitment [Art. 6(1)(f)].
Legitimate interest balancing: Where we rely on legitimate interest, we have conducted a balancing assessment to ensure that our interests do not override the fundamental rights and freedoms of the data subjects.
4. Storage, Transfers and Retention
4.1 Data storage and international transfers
We may share personal data with:
Personal data collected through the Service is stored and processed within the EU/EEA, primarily in Ireland (Teamtailor’s hosting infrastructure). Where data is transferred to countries outside the EU/EEA, such transfers are protected by:
4.2 Key subprocessors
A complete list of subprocessors is available upon request.
4.3 Retention periods per data category
5. Users’ Rights
Under the GDPR, Users have the following rights:
To exercise these rights, please contact us using the details in Section 9.
6. Security
We implement appropriate technical and organisational measures to protect personal data, including:
While we take all reasonable precautions, transmissions over the internet cannot be guaranteed to be fully secure. Users are responsible for keeping their login credentials confidential.
We may use aggregated, fully anonymised data for analytics and market research. Such data cannot be used to identify any individual and is therefore not personal data.
7. Use of Artificial Intelligence in Recruitment
As part of our recruitment processes, CTW uses systems supported by artificial intelligence (“AI systems”) to assist in the management and evaluation of applications. This section provides the transparency required under GDPR Art. 13(2)(f), Art. 14(2)(g), and the EU AI Act (Regulation (EU) 2024/1689).
7.1 AI systems used in recruitment
7.2 How AI is used and how it is NOT used
AI systems are used as decision-support tools to assist our recruiters and hiring teams. They help structure information, reduce administrative burden, and improve consistency in documentation.
AI systems are not used to make autonomous recruitment decisions. No candidate is automatically rejected, ranked, scored, or selected by an AI system without meaningful human review.
AI outputs (e.g., Metaview interview notes) serve as supplementary documentation; recruiters independently form their assessment of each candidate.
We do not use emotion recognition, sentiment analysis, or biometric categorisation in our recruitment process.
7.3 Human oversight
All recruitment decisions, including candidate progression, evaluation, and selection, are made by qualified human recruiters and hiring teams who:
7.4 Interview
When transcript is used during an interview:
The candidate is informed before the interview that an AI-assisted transcription tool will be used.
The candidate may request a non-AI/manual note-taking alternative without any negative impact on their candidacy. The interview proceeds normally without AI assistance.
The transcript output is used solely for the recruitment process.
AI-generated transcriptions are deleted upon conclusion of the recruitment process for the specific vacancy, unless the candidate consents to extended retention.
7.5 Automated decision-making
CTW does not subject candidates to decisions based solely on automated processing that produce legal or similarly significant effects. All AI tools in our recruitment process operate in an advisory capacity with meaningful human oversight.
7.6 Candidate rights regarding AI processing
In addition to the rights listed in Section 5, candidates have the following rights specifically related to AI-assisted processing:
7.7 Fairness, accuracy and bias mitigation
We take the following measures to ensure AI systems do not introduce bias or unfairness:
7.8 Legal basis for AI processing
7.9 Data protection impact assessment
Data Protection Impact Assessments (DPIAs) are carried out where processing activities are likely to result in a high risk to individuals’ rights and freedoms, as required by Art. 35 GDPR and Art. 26(9) of the EU AI Act.
8. Security
When using the Service, information may be stored as cookies. We use cookies to improve the user experience and gather usage statistics. The information collected may, in some instances, constitute personal data and is regulated by our Cookie Policy, accessible through the Service. Users may disable cookies via browser settings, which may affect Service functionality.
9. Contact
We may update this Privacy Policy at any time.
For questions about this Privacy Policy, to exercise your data protection rights, or for any other matter related to our handling of personal data, contact CTW’s Data Protection Officer using the e-mail privacy@criticaltechworks.com.
