SERIES: 30 PERSONAL DATA PROTECTION COMPLIANCE SCENARIOS IN EVERYDAY BUSINESS OPERATIONS #1: COLLECTING CANDIDATE DATA - HOW MUCH IS ENOUGH?
- loanlelawlinkvn
- Mar 30
- 2 min read
In recruitment practice, many companies tend to request a full set of application documents from candidates at the very early stage, including information or materials that are not yet necessary at the time of application. While this approach may help avoid “missing documents later on,” it also increases personal data compliance risks.
It is important to note that compliance obligations do not arise only when data is used for improper purposes; they can begin as early as the point where excessive data is collected beyond what is actually required at each stage of the recruitment process. The data needed for initial screening is typically different from the data required at later stages such as in-depth interviews, reference checks, or pre-onboarding.
The more data collected prematurely, the greater the burden on storage, access control, security, and accountability. By contrast, a recruitment process designed with a phased (layered) data collection approach enables companies to operate efficiently while maintaining better control over necessity and scope of processing.
📌 Recommendations for employers:
Companies should consider developing a recruitment data collection checklist aligned with each stage of the hiring process, rather than applying a one-size-fits-all document requirement for all candidates.
📌 Mini-checklist:
✅ Identify what data is truly necessary at the initial screening stage;
✅ Separate data required for interviews, reference checks, and pre-onboarding;
✅ Avoid requesting identification documents or excessive materials before they are genuinely needed;
✅ Limit access to candidate profiles to authorized personnel only;
✅ Define retention and handling procedures for unsuccessful candidates’ data.
In personal data governance, collecting data that is appropriate in scope and timing is always a safer approach than collecting in advance “just in case.”
Legal reference: Law on Personal Data Protection No. 91/2025/QH15 and its implementing regulations, particularly provisions on data processing principles, purpose limitation, data minimization (necessity), and data security obligations.
CTA: To download the recruitment data collection checklist, please refer to the link here:
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Article: Prepared by LLVN.
Image: LLVN
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