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GDPR & Compliance

EU Data Privacy Laws and Recruitment Technology: What You Need to Know in 2026

9 min readMarch 2, 2026

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The Expanding Regulatory Landscape

European recruitment technology operates under a growing web of data privacy regulations. Beyond GDPR, the EU AI Act (Regulation 2024/1689) now classifies AI systems used in employment decisions as “high-risk,” imposing new transparency, documentation, and human oversight requirements. Understanding these overlapping frameworks is critical for any organisation using video interview platforms.

GDPR: The Foundation

The General Data Protection Regulation remains the cornerstone. Key provisions for recruitment technology include:

  • Article 22: Candidates have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects. This directly impacts AI-scored interviews.
  • Articles 13 to 14: Transparency requirements mandate clear information about how candidate data is processed.
  • Article 35: Data Protection Impact Assessments are required for high-risk processing, which often includes large-scale video interview programmes.

Enforcement is real: €355 million in employment-related GDPR fines have been issued across 162 cases (CMS Enforcement Tracker, 2025), and the maximum penalty is €20 million or 4% of global turnover.

The EU AI Act: New Rules for Recruitment AI

The AI Act entered into force in August 2024, with a phased compliance timeline. AI systems used for “recruitment and selection of natural persons” are classified as high-risk under Annex III. This means:

  • Mandatory risk management systems and technical documentation
  • Data governance requirements for training datasets
  • Transparency: candidates must be informed they are interacting with an AI system
  • Human oversight: meaningful human review of AI-assisted hiring decisions
  • Registration in the EU AI database before deployment

Full compliance for high-risk systems is required by August 2026.

ePrivacy and Cookie Regulations

The ePrivacy Directive (and the forthcoming ePrivacy Regulation) governs electronic communications. For recruitment platforms, this affects:

  • Cookie consent for candidate-facing interview portals
  • Tracking technologies used to monitor candidate engagement
  • Email and messaging communications with candidates

Cross-Border Data Transfers

Following the Schrems II decision and the EU-US Data Privacy Framework, organisations must carefully manage international data transfers. Using a video interview platform that stores data outside the EEA requires either an adequacy decision, Standard Contractual Clauses (SCCs), or Binding Corporate Rules (BCRs).

Practical Compliance Checklist

  1. Map all personal data flows in your recruitment technology stack
  2. Conduct a DPIA for video interview processing
  3. Update privacy notices to cover AI Act transparency requirements
  4. Ensure meaningful human oversight of AI-assisted decisions
  5. Verify your platform stores data within the EU/EEA
  6. Implement automated retention and deletion policies
  7. Review vendor DPAs and sub-processor lists annually

Why StormInterview Is Built for European Compliance

StormInterview is EU-based and EU-hosted. AI features include full transparency disclosures, human-in-the-loop review, and audit trails designed for both GDPR and AI Act compliance. Data never leaves the EU. At €79/month, compliance is built into every plan.

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