Compliance isn't a feature
we added later.

We don't pretend to be low-risk.

AI systems used to filter or evaluate job applications are listed in Annex III of the AI Act. Some vendors in this space describe themselves as "assistive" to stay out of that box. We do the opposite: we assume the classification applies and build for the obligations that come with it. That is a better place to be when your legal team asks, and it is the honest description of what the product does.

• Human oversight by design. Outputs are information for a person. The system has no path to reject, rank out or filter a candidate on its own.
• Transparency to the people affected. Every signal is written so it can be shown to a candidate: what we found, why it matters, how to check it.
• Logging. For every verification we record the signal library version, detected signals, score, badge and timestamp. The recruiter's review (who, what, when) is recorded separately in the decision history, as the recruiter's own.
• Documentation for the deployer. Instructions for use, the description of checks and their data flows, and the division of responsibilities between us and you are part of the customer documentation.

Obligations for Annex III systems apply from December 2027 after the 2026 amendment of the Act. We are not waiting for the date.

You are the controller. We are the processor.

Candidate data lives in your ATS. TalentShield processes it on your documented instructions, under a Data Processing Agreement that lists every sub-processor by name, location and purpose. Public professional profile information is personal data too, and we treat it that way: it is processed under your legitimate interest, only for the checks you switch on, and never bought or enriched for other purposes.

• No automated decision-making in the meaning of Article 22: the product informs a human decision, it does not make one.
• Data minimisation per check: deterministic checks run locally; open checks send the model only what that check needs; enrichment sources are configurable per customer and off by default in pilots.
• Candidate rights (access, rectification, erasure, objection, human intervention) are exercised through you as the controller; requests that reach us are forwarded to you within five business days.
• DPIA support: we provide the description of processing, data flows and safeguards your assessment needs.

Hosted in the EU. Processed in the EU.

The application and its database run in Frankfurt. Verification reports are stored in Nuremberg. AI processing runs on Azure OpenAI Service in Microsoft's EU Data Zone, with our resource and stored data in Sweden; inputs and outputs are not retained and are not used for training. Transactional email leaves through an EU region. Encryption in transit (TLS 1.2+) and at rest (AES-256), access controls with multi-factor authentication, and separate accounts per system are the baseline, not the premium tier.

We do not hold ISO 27001 or SOC 2 yet. We say so, and the Security & Architecture Overview describes the compensating controls in detail.

Sub-processors for candidate data.

Every third party that can receive candidate data, by name. The full list with transfer mechanisms and dated prior versions is Annex 3 of the DPA.

Last updated 5 October 2026.

What you get for your review.

• Security & Architecture Overview
• Data Processing Agreement with Annexes (processing description, technical and organisational measures, sub-processors)
• AI Governance Statement
• Terms of Service, Design Partner Agreement for pilots
• Answers to standard security questionnaires, on request
• Privacy Policy

The Privacy Policy is public. The DPA, Security & Architecture Overview and AI Governance Statement are sent on request, usually the same day. Ask for the pack in the demo form or write to privacy@talentshield.app.