RecruitingManatal and the GDPR: agreement, role and data location.
Manatal is a recruiting tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in United States. Below: what to check and how to declare it.
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In short
- Category
- Recruiting
- Usual role
- Usually a processor
- Data location
- Usually United States
- Agreement
- Published by the vendor
What does Manatal do with personal data?
Publish job offers, receive applications and manage the hiring process. That is how Privacyboard describes a typical use of Manatal, as a starting point you can edit.
The data usually involved: candidate names, contact details, CVs, cover letters, interview notes and assessments.
Is Manatal a processor or a controller?
Most customers use Manatal as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for recruiting tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Manatal store personal data?
Manatal usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs.
What Manatal says (read on 2026-11-05): Services “hosted on Amazon Web Services (AWS) in the United States” Source: https://www.manatal.com/data-processing-addendum
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.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Which legal basis usually applies to Manatal?
For the usual use of Manatal, 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 Manatal have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Manatal 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: Data Processing Addendum, effective 7 Sep 2026, with “Manatal” as processor (no legal entity named). Says services are hosted on AWS in the United States; transfers use 2021 SCCs (Modules Two/Three), UK Addendum and Swiss adaptation.
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 Manatal agreementHow to declare Manatal
- 1
In your privacy policy
Name Manatal 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 Manatal 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 Manatal 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 Manatal
- 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 Manatal GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Manatal 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 Manatal have a DPA?
Yes. Manatal 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://www.manatal.com/data-processing-addendum.
Is Manatal a data processor?
Usually, yes. Most customers use Manatal as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use Manatal?
For the usual use of Manatal, 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 Manatal store data?
Manatal usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs. What Manatal says (read on 2026-11-05): Services “hosted on Amazon Web Services (AWS) in the United States” Source: https://www.manatal.com/data-processing-addendum
Do I need to mention Manatal in my privacy policy?
Yes, if Manatal 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 Manatal to my vendor list?
In Privacyboard, pick Manatal 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 Manatal. 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.