Recruiting agency data: what can be licensed?

Why are recruiting records harder than other agency records?

A design studio's revision log is about a layout. A recruiter's pipeline is about people: who applied, what they earn, why they were turned down. The records that make a recruiting agency valuable to a lab are the same records that belong, in a real sense, to candidates who never agreed to AI training.

Buyers know this. Scale AI's page rules out identities of staff or customers entirely, and micro1 undertakes not to pass data on to anyone until identifying details have been anonymized. Neither statement makes candidate data safe to hand over; they describe what the buyer will do after you already have.

What is off limits?

Which laws come into it?

State privacy laws increasingly cover job applicants, not only consumers, and video interviews raise biometric questions: voiceprints and face geometry can be biometric data under Illinois' BIPA, Texas' CUBI and Washington's biometric law. Your candidate privacy notice is the first document to read, because it records what you told people you would do with their information.

Client contracts matter too. A staffing or retained search agreement usually treats the client's hiring plans as confidential, and some assign the shortlist and search materials to the client.

What could a recruiting agency license?

• Stage-by-stage pipeline timings, with every candidate and client identifier removed
• Role specifications rewritten so no employer, team or pay band can be traced
• Outreach sequences, screening rubrics and interview guides you wrote
• Search playbooks, SOPs and recruiter onboarding material

Only records the agency owns, or may license, can go at all. Scrub personal details yourself whatever the buyer promises about de-identification, and put the agreement and your candidate notice in front of your own lawyer before signing.

Questions from recruiting agencies

Can a recruiting agency sell resumes to AI companies?

Treat that as a no. A resume is personal information about a candidate who shared it to be considered for a role. Licensing it for AI training is a new use they never agreed to, and the buyers we read say they remove or refuse identities anyway.

What if we remove the names?

A resume without a name still carries a career history, employers, dates and often a location, which together can identify a person. De-identifying free text that rich is hard to do well. Leave resumes and interview notes out.

Are job descriptions ours?

Often they are the client's, or written from the client's confidential hiring plans. A role specification rewritten so no client, team or salary band can be traced is closer to being yours, but check the client terms.

Does our candidate privacy notice matter?

Yes. It sets out what you told candidates you would do with their information. If it does not mention licensing to third parties for AI training, that use is outside what they were told.

Which buyers fit a recruiting agency?

None of the four buyers we track names recruiting records specifically. micro1's list includes process documentation, SOPs and operations records, and Scale AI names CRM and HR records, as each page read on 7 Nov 2026.