Additional Provisions for Recruiters and Employers

In Short: If you are using our Services to source talent, you are a "Data Controller" in your own right. You agree to treat our Members' data with the highest level of confidentiality, use it only for legitimate hiring purposes, and respect the bias-prevention safeguards we have put in place.

1. Purpose Limitation

As a Recruiter or Employer, you are granted access to Member data solely for the purpose of evaluating candidates for specific, legitimate job opportunities. You are strictly prohibited from:

• Using Member data for marketing, or selling it to third parties.

• Scraping, harvesting, or indexing Member profiles to build external databases.

• Sharing Member contact details with any party outside of your immediate hiring organization without explicit consent.

2. Prohibition of Tertiary Databases (The Anti-Hoarding Rule)

Access to Member data is granted strictly on a "Per-Candidate, Per-Role" basis. You are strictly prohibited from:

• Database Population: Exporting, scraping, or transferring Member data to populate any general, tertiary, or "just-in-case" internal database or Applicant Tracking System (ATS) without a current, specific hiring intent.

• Unauthorized Retention: Storing candidate profiles for which you do not have an active and immediate hiring interest.

• Mandatory Disclosure: In the event that Graduate Pathfinder discovers the creation of a tertiary database in violation of these terms, you are legally required to immediately disclose the full extent of the stored data to us. This is to ensure we can fulfill our duty to inform the Data Subjects of the unauthorized processing.

Legal Note: Violation of this provision constitutes a material breach of contract and a violation of the Principle of Transparency (Article 5 GDPR). We maintain a zero-tolerance policy for data hoarding.

3. Data Stewardship and Security

Once you view or download a Member’s professional documents (CVs, Resumes, etc.), you assume Controller responsibility. You agree to:

• Storage: Maintain industry-standard security measures (encryption, access controls) to protect candidate data.

• Retention: Delete candidate data once the specific role has been filled or if the candidate is no longer under consideration, unless you have a separate legal basis to retain it.

• Breach Notification: Immediately notify Graduate Pathfinder (within 24 hours) if any data sourced from our platform is compromised.

4. Respecting Bias-Prevention Controls

Our platform utilizes "Privacy by Design" features (such as hidden profile pictures and separated demographic data) to ensure fair hiring.

You agree not to attempt to circumvent these protections.

You shall not use any demographic insights provided in our aggregate reports to discriminate against individual candidates.

5. External Recruiter Restricted Access

External recruiters acknowledge that they are granted "Partial Access" to the Member pool.

• You may only share Anonymized Profiles with your own clients until the Member has expressed interest in a specific role.

• Misrepresenting your relationship with Graduate Pathfinder to candidates is grounds for immediate account termination.

6. AI Processing of Commercial Content

We use AI to make your hiring more efficient. By posting a role, you grant Graduate Pathfinder a license to analyze your Job Descriptions (JDs) and company information to:

• 6.1. Matching: Extract key skills and requirements for merit-based Candidate Matching.

• 6.2. Trends: Perform de-identified Trend Analysis (e.g., salary benchmarking) to improve our market insights.

• 6.3. Interview Aids: Generate interview questions or assessment criteria based on your specific role requirements.

7. Vetting and Compliance

Graduate Pathfinder reserves the right to audit your use of Member data. Failure to comply with these provisions or relevant data protection laws (e.g., UK GDPR) will result in the immediate revocation of access and potential reporting to the Information Commissioner’s Office (ICO).