RecruitingCheckr and the GDPR: agreement, role and data location.
Checkr is a recruiting tool. Its role depends on the activity, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Recruiting
- Usual role
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Checkr do with personal data?
Publish job offers, receive applications and manage the hiring process. That is how Privacyboard describes a typical use of Checkr, as a starting point you can edit.
The data usually involved: names, Employee data, cover letters, interview notes, assessments
Is Checkr a processor or a controller?
as a background-check provider Checkr handles FCRA-regulated data and disputes directly, outside the processor role.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does Checkr store personal data?
Checkr does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to Checkr?
For the usual use of Checkr, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Reviewing an application is a step the candidate asked for before a possible contract; keeping a CV for other openings rests on a legitimate interest or on consent.
The interest you would state: “Assessing applications and keeping in touch with candidates for future openings, for a limited time.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Tell candidates how long you keep their data, often two years in France, and delete it after. The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does Checkr have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Checkr publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
What we noted when we opened the page: Checkr, Inc. Data Protection Addendum, last updated 1 Mar 2025. Data may be processed in the US or elsewhere; relies on the DPF and, if needed, SCCs (Module 2) and the UK Addendum. FCRA-covered data is excluded.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the Checkr agreementHow to declare Checkr
- 1
In your privacy policy
Name Checkr as a recipient, say what it is used for (publish job offers, receive applications and manage the hiring process) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Checkr with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Checkr to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Checkr
- Set and apply a retention period for rejected candidates.
- Tell candidates in the job offer or the form who processes their data and how to reach you.
- Check what any automated screening or scoring does, and keep a person in the decision.
- Check the region and any transfer outside the EEA.
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Questions, answered.
Is Checkr GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Checkr is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Checkr have a DPA?
Yes. Checkr publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://checkr.com/dpa.
Is Checkr a data processor?
It depends on the activity. as a background-check provider Checkr handles FCRA-regulated data and disputes directly, outside the processor role.
Which legal basis applies when I use Checkr?
For the usual use of Checkr, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Reviewing an application is a step the candidate asked for before a possible contract; keeping a CV for other openings rests on a legitimate interest or on consent. The interest you would state: “Assessing applications and keeping in touch with candidates for future openings, for a limited time.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Checkr store data?
Checkr does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention Checkr in my privacy policy?
Yes, if Checkr handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Checkr to my vendor list?
In Privacyboard, pick Checkr from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with Checkr. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.