When ZipRecruiter acts as a service provider for an employer client, it processes your data under the employer's instructions, and if you want to access or delete your data, ZipRecruiter will direct you to contact the employer rather than handling your request directly.
This analysis describes what ZipRecruiter's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
If your personal data is processed by ZipRecruiter on behalf of an employer, your rights requests go to the employer, not ZipRecruiter, which may create delays or barriers to exercising your data rights.
Job seekers whose data is processed by ZipRecruiter as a service provider for an employer client must direct data access or deletion requests to the employer, not to ZipRecruiter, which means your ability to exercise privacy rights depends on the employer's responsiveness and processes.
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"In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals (data subjects) whose Personal Data we process. Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data, or have other request, we will provide you with the data controller's contact information, so you can contact them directly.— Excerpt from ZipRecruiter's ZipRecruiter Privacy Policy
REGULATORY LANDSCAPE: The controller/processor distinction is a foundational GDPR concept; under GDPR Article 28, processors must act only on controller instructions, and data subjects generally exercise their Article 15-22 rights against the controller. This structure is legally standard but practically may disadvantage data subjects who are unaware of who the data controller is. Under CCPA, a service provider relationship similarly limits ZipRecruiter's obligations to data subjects, directing rights requests to the business that engaged ZipRecruiter. GOVERNANCE EXPOSURE: Medium. The policy correctly describes the processor role but the practical implication, that job seekers may not know which employer client controls their data, creates a transparency and rights access gap. The policy's acknowledgment that 'in rare instances, circumstances may necessitate ZipRecruiter assisting you' provides a limited safety valve. JURISDICTION FLAGS: EEA and UK users have enforceable rights against data controllers under GDPR, but must first identify the correct controller. The ICO and other EU DPAs have addressed the challenge of individuals identifying the correct controller in complex data supply chains. California users have CCPA rights against the business that engaged ZipRecruiter. CONTRACT AND VENDOR IMPLICATIONS: Employer clients contracting with ZipRecruiter for job alert or recruitment services become data controllers for the candidate data processed, and must ensure their own GDPR Article 13/14 notices and rights response mechanisms are in place. Data processing agreements between ZipRecruiter and employer clients should be reviewed to confirm Article 28 compliance. COMPLIANCE CONSIDERATIONS: Legal and procurement teams at employer organizations should confirm that ZipRecruiter data processing agreements include appropriate sub-processor restrictions, audit rights, data breach notification timelines, and deletion obligations. Job seekers who receive no response from an employer client to a rights request may escalate to the relevant DPA.
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If your personal data is processed by ZipRecruiter on behalf of an employer, your rights requests go to the employer, not ZipRecruiter, which may create delays or barriers to exercising your data rights.
Job seekers whose data is processed by ZipRecruiter as a service provider for an employer client must direct data access or deletion requests to the employer, not to ZipRecruiter, which means your ability to exercise privacy rights depends on the employer's responsiveness and processes.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by ZipRecruiter.