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Template policy: Handling sensitive applicant data
Practical template for companies: roles, technical protections, mandatory training and documentation for handling sensitive applicant data in Switzerland.
Quick answer
This template defines roles, technical protections, training obligations and documentation so your Swiss company can handle sensitive applicant data securely. Use it as a basis and adapt it to your HR systems, IT setup and Swiss data protection requirements.
Purpose and scope
This policy governs collection, processing, storage and deletion of sensitive applicant data. It applies to employees, managers, HR staff, IT administrators and external providers involved in the recruitment process. Sensitive applicant data includes health information, criminal record extracts, race/ethnicity, political opinions, religious beliefs, union membership and biometric data.
Roles and responsibilities
Data protection officer: Monitor compliance, perform risk assessments and act as contact point for incidents. HR staff: Collect only necessary data, review permissions and maintain secure applicant records. IT administrators: Implement technical safeguards, manage access rights and log system events. Managers: Ensure team compliance with the policy. External providers: Process data only under a written data processing agreement and proven security measures.
Privacy principles
Data minimisation: Collect only what is necessary for selection decisions. Purpose limitation: Use applicant data only for recruitment and permitted legal purposes. Storage limitation: Delete sensitive data once the purpose ends or after defined retention periods. Transparency: Inform applicants about purposes, legal bases and retention periods.
Technical and organisational safeguards
Access control: Role-based access and least-privilege settings in HR systems. Encryption: Encrypt data at rest (servers, backups) and in transit (email, uploads). Logging: Keep access and change logs for applicant files. Device security: Full-disk encryption and strong authentication on laptops/tablets. Physical security: Access rules for HR areas and secure disposal for paper documents.
Training and awareness
All staff with applicant contact complete a basic data protection course. HR and IT receive in-depth annual training on data access, retention and incident reporting. Training attendance is recorded and retained.
Documentation and audits
Maintain a record of processing activities for recruitment data. Keep risk assessments, data processing agreements, training records and access control logs. Conduct at least annual internal audits to verify policy implementation. Archive audit reports and corrective action plans.
Frequently asked questions
Which applicant data counts as sensitive?
Sensitive data includes health information, religion, political opinions, ethnic origin, union membership, sexual life, biometric data and criminal record extracts.
How long can I retain applicant data?
Retention depends on purpose. Keep recruitment data only as long as needed for selection. For talent pools or other follow-up uses, obtain explicit consent and set a clear retention period.
Do I need a data processing agreement with external providers?
Yes. External providers processing applicant data should sign a written agreement covering security requirements, processing activities and responsibilities.
What to do in case of a data breach?
Block the affected access, document the incident, notify the data protection officer and assess reporting obligations to authorities and affected applicants.