madita.ai

Compliance process

Steps to full compliance

Not legal advice

Using Madita requires you to update your existing privacy policy. Candidates must be informed of the updated version before they are uploaded into Madita. Please review your current privacy policy and extend it for the use of Madita. The following information does not constitute a template, but it can support you in drafting your privacy policy.

1. Update your privacy policy

As part of your application, we may invite you to take an AI-led interview conducted by Madita (a product of HeyJobs GmbH) to assess your suitability for the target position. The cooperation with Madita as a data processor is governed by a data processing agreement covering all the following steps.

Step 1 (before the invitation)

Your application documents are processed by the provider using AI in order to generate suitable interview questions matched to the profile of the target role and to draft and send you an AI-generated invitation email. For this purpose we process the following data: first name, last name, email address, phone number, and application documents. No assessment of your application documents takes place. The legal basis for this processing is Art. 6 (1) lit. f GDPR (legitimate interest).

Step 2

You will receive an invitation to the AI interview. Participation in the AI interview is voluntary and not a prerequisite for the application process. For the AI interview we process the following data: the contact data listed in Step 1 as well as your interview answers (audio recording of the interview and automatically generated transcript). The interview is processed by an AI system based on role-specific criteria. The final decision regarding the further application process is made exclusively by a human. The legal basis for this processing is Art. 6 (1) lit. a GDPR (consent).

Step 3

After the application process is completed, your interview data (voice recording, transcript, evaluation and application documents) is deleted no later than six months after the last activity in your application process. The employer may set a shorter period. The data is not used to train AI models.

You can exercise your right to withdraw consent (Step 2) and your right to object (Steps 1 and 3) via the contact channels listed in this privacy policy.

2. Document legitimate interest assessments

Not legal advice: This information may support you in drafting your own legitimate interest assessment.

1. Legitimate interest

The employer has a legitimate business interest in conducting application processes in a structured, efficient and comparable way for all candidates. The use of an AI-supported interview system enables standardised, role-specific questions and reduces subjective bias in the selection process.

Result: legitimate interest established.

2. Necessity

The processing of application documents by the data processor is technically necessary to generate candidate-specific interview questions tailored to the requirements profile of the target role. Without this step only a generic interview, not tailored to the candidate, would be possible. Only data required for question generation is processed. No assessment of the documents, no scoring and no profiling takes place.

Result: processing is necessary and proportionate.

3. Balancing of interests

For the employer: structured and efficient application process with standardised, role-specific questions.

For the candidate: the impact is minimal. No assessment of the documents takes place. The data is used solely for the development of interview questions and is not further processed for other purposes. The candidate has actively submitted the application documents as part of their application and can reasonably expect that these will be processed during the application process.

Safeguards: contractual binding of the data processor (DPA pursuant to Art. 28 GDPR), purpose limitation, deletion after completion of the application process, transparency through the privacy policy.

Result: the legitimate interest of the employer prevails. The processing is foreseeable for the candidate and the impact on their fundamental rights is low.

Right to object (Art. 21 GDPR)

Candidates can object to the processing at any time. An objection to this processing step has the consequence that no AI interview can be conducted. The right to object is disclosed in the employer's privacy policy.

3. Ensure candidate acknowledgement

Make sure that every candidate has acknowledged the updated version of your privacy policy before their data is uploaded into Madita.

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