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TalentInitiator

Security and data residency

Records, documents and interview recordings are stored in Canada. The AI steps, from reading résumés to evaluating answers and transcripts, run in the United States, and we say so before they happen. Here is the whole picture, including what is not connected yet.

The demo runs on fictional people and companies, with an offline evaluator. What you type into it reaches none of the providers below.

Residency statement

Candidates read these exact words before they apply and before an interview is recorded. Our data processing agreement, which we are preparing with counsel, will carry the same text.

Your candidate records, documents and interview recordings are stored in Canada (AWS Canada (Central), Montréal). If you record your interview answers, the audio is transcribed in Canada (Amazon Transcribe, Canada (Central)). We use AI services operated by Anthropic in the United States, under contract. Reading your résumé sends the document you submitted, contact details included. The pre-screening chat sends the messages you write, and outreach drafts use your first name. Your profile, written answers and interview transcripts are evaluated with names and contact details removed. Under our commercial terms, none of this information is used to train AI models. Email and SMS are delivered by providers listed on our sub-processor page, some of which operate outside Canada. Information processed outside Canada may be accessible to the authorities of that country under its laws.

See every sub-processor and its location 

What goes where

Each kind of information, the service that handles it in our production cloud deployment and where that service runs. That deployment takes real candidate data from release 0.2; until then the product runs as the demo. A confirmed location says where a service runs, not that it is already in use.
InformationProviderLocationLocation confirmed
Candidate recordsSupabaseCanada (AWS Canada (Central)); backups confirmation pendingConfirmation pending
Résumés, documents and interview recordingsAmazon Web ServicesThe application’s data keys move to AWS Key Management Service before any customer data is stored. Until then, the cloud service holds no customer data.Canada (Central), MontréalConfirmed
The application itselfVercelMontréal (yul1) for function execution; logs and build data location: confirmation pendingConfirmation pending
Interview audio, for transcriptionAmazon TranscribeNot connected in this release. Recorded interviews are offered to candidates only once it is; written answers are not affected.Canada (Central)Confirmed
Résumés, chat messages, written answers and transcripts, for AI reading and evaluationAnthropicUnited StatesConfirmed
Email to candidatesAmazon Simple Email ServiceCanada (Central)Confirmed
Text messages to candidatesTwilioNot connected in this release. Text messages go through it only once STOP replies reach the suppression list automatically.United StatesConfirmed
Error reports, with personal information removedSentryNot connected in this release.United StatesConfirmed

Status of the cloud service

These parts are not in service in this release. No customer data goes into the cloud service until the ones planned for release 0.2 are in place (target: Q1 2027).
Part of the serviceIn this releasePlanned
Sign-in for customer accountsDemo sign-in only, for fictional dataRelease 0.2, target Q1 2027
Data keys in AWS Key Management Service, Canada (Central)Key file on the application serverRelease 0.2, target Q1 2027
Delivery, bounce and opt-out reports from the email and text providersNot connected; text messages stay unsentRelease 0.2, target Q1 2027
Interview transcription with Amazon Transcribe, Canada (Central)Not connected; candidates answer interviews in writingRelease 1.0, target Q4 2027
Error tracking with Sentry, personal information removedNot connected; no error report leaves the applicationNot scheduled yet

Encryption and access

  • Every connection to the cloud service uses HTTPS.
  • Names, email addresses, phone numbers and street addresses are encrypted inside the application with AES-256-GCM, using a separate data key for each customer organization.
  • Data keys are kept apart from the database. In this release they are held in a key file on the application server; they move to AWS Key Management Service in Canada (Central) before the cloud service stores any customer data.
  • Duplicate checks and searches by email or phone use keyed hashes, so an address can be matched without being decrypted.
  • Résumés and recordings are encrypted by the storage service and opened only through short-lived signed links.
  • Each customer’s records are kept apart by row-level security in the database, on every query.
  • Links sent to candidates and clients are random, stored only as hashes, limited to one person and set to expire.
  • No personal information ever appears in a web address.

Audit log and retention

Every view of personal information and every change is written to the audit log, which is kept 3 years. Records are anonymized first, then deleted, when their time is up.
RecordKept forWhy
Candidate records with no stricter rule3 years by defaultSet by each customer, per type of record.
Interview recordings90 days after the interview, by defaultTranscripts stay with the application. A customer may shorten the period.
Postings, application forms and outcome notices3 yearsRequired in Ontario, and kept even after a deletion request, reduced to what the rule needs.
Breach records24 monthsRequired by federal breach regulations.
Unsubscribed addressesAs long as we send messagesKept as a hash so the person is never contacted again.

A legal hold stops anonymization and deletion for as long as a complaint, audit or proceeding needs the records, and every screen that offers deletion says so.

If something goes wrong

Our process for a breach of security safeguards, from the first alert to the record we keep.

  1. Contain and assess

    We stop the exposure, then work out what was affected and whether there is a real risk of significant harm to anyone.

  2. Tell the customers affected

    We notify each customer organization whose information was involved without delay, with what happened, what was affected and what we have done, so they can meet their own obligations to their candidates.

  3. Report where the law requires it

    Where there is a real risk of significant harm, the breach is reported to the Privacy Commissioner of Canada and the people affected are notified as soon as feasible.

  4. Keep a record

    Every breach is recorded, whether or not it had to be reported, and the record is kept 24 months.

Customers keep their own breach register in the compliance centre, with the harm assessment checklist, the dates reported and notified, and a notification template.

Due-diligence pack

For your privacy or security review, we send:

We do not hold a SOC 2 report or an ISO 27001 certificate today. The pack says so plainly rather than implying one.

Ask for the pack
  • A description of the data flows: what goes where, and why
  • The sub-processor list, with locations
  • The list of AI features and models, with each feature’s evaluation results
  • The residency statement and the transfer-assessment template for Quebec
  • Our data processing agreement, once counsel has reviewed it (Pending legal review). We are preparing it now, and it is signed before any customer’s real data comes in.
  • The human-rights impact assessment summary