Predictable Hire Privacy Notice

Last updated: May 26th, 2026

This privacy notice explains how Predictable Hire handles personal data. It covers candidates we contact or work with, contacts at our client companies, and visitors to our website. We have written it in plain language. If anything is unclear, email scott@predictablehire.com and we will explain.

Who we are

Predictable Hire is a recruitment business operated by Scott Entwistle as a sole proprietorship (Einzelunternehmen) registered in Germany. We act as an independent data controller for the personal data we process. The contact for any data protection question is:

Scott Entwistle Predictable Hire scott@predictablehire.com

We have not appointed a Data Protection Officer because we are not legally required to do so under GDPR or German law. Direct any privacy question to the address above.

Who this notice applies to

It applies to three groups:

Candidates. People we contact about a role, people who apply to us directly, and people whose profiles we review for potential opportunities.

Client contacts. People who work for our client companies and engage with us about a search.

Website visitors. People who visit predictablehire.com.

The next sections explain what we collect, why, and how we handle it for each group.

Information we collect about candidates

We collect:

Identifying information: name, email, phone number, location, professional photo where available.
Career information: CV, work history, education, qualifications, languages, salary expectations, notice period, work authorization status.
Information from public professional profiles such as LinkedIn.
Notes from our conversations with you, including recordings of calls where you have given consent.
Information third parties provide about you, such as references where you have agreed to them being contacted.
Where you proceed to a client interview, the results of any background check we run on your behalf.

We do not seek out special category data (such as health information, ethnic origin, political views, religious beliefs, or sexual orientation). If you choose to share any of this with us, we only process it where the law allows and only to the extent necessary.

Why we process candidate data, and on what legal basis

Sourcing and identifying potential candidates from public sources. Legitimate interest in matching candidates to relevant roles.

Assessing your suitability for a specific role. Legitimate interest, or steps taken at your request prior to entering into a contract.

Submitting your profile to a client we believe is a strong match. Legitimate interest, with your prior agreement before any submission.

Conducting background checks where the role requires them. Legitimate interest, with your prior consent for the specific check.

Retaining your profile for future opportunities. Legitimate interest, with the right to object at any time.

Complying with legal obligations (tax, accounting, defending claims). Legal obligation.

Our legitimate interest is running a recruitment business that delivers genuine, qualified candidates to clients while giving candidates access to relevant opportunities. We balance this against your privacy rights. You can object to processing based on legitimate interest at any time by emailing scott@predictablehire.com.

We will never submit your profile to a client without your agreement.

Information we collect about client contacts

We collect your name, job title, employer, business email, business phone, and notes from our conversations and meetings. Where you have given consent, we may record calls for note-taking purposes.

We process this data to perform our services under our agreement with your employer, and on the basis of our legitimate interest in maintaining the commercial relationship.

How we use AI tools

We use AI tools across our work, including for drafting outreach, identifying potential matches between candidates and roles, taking meeting notes, and improving the quality of our communications. These tools assist us. They do not replace us. Every decision about whether to contact a candidate, submit a candidate to a client, or progress a candidate through a search is made by a human, not by an algorithm. We do not make solely automated decisions about candidates within the meaning of Article 22 GDPR.

Call recordings. We record calls using a local recording tool that captures audio on our device and generates AI-assisted notes. Before any call is recorded, we ask for your consent at the point of booking through our scheduling tool (Cal.com), which includes a recording disclosure and acknowledgment checkbox. You may decline recording at booking or at the start of any call. Recordings and AI-generated notes are stored alongside your candidate or client record and deleted on the same schedule as that record (see "How long we keep your data" below).

Who we share data with

We share candidate profiles with the specific client who has briefed us on a role, and only after you have agreed to be submitted.

We use a small number of service providers (sub-processors) to run the business. We have data processing agreements in place with them where required. The current categories and providers are:

Email and document storage: Google Workspace (US-based, EU data processing terms)
Sourcing platform: LinkedIn Recruiter (US-based, EU data processing terms)
Call recording and meeting notes: Granola.ai (local recording with cloud-based AI processing)
Booking and scheduling: Cal.com
Bookkeeping: sevDesk (Germany-based)
Website hosting: Wix (US/Israel-based, EU data processing terms)

We update this list when we change tools. Categories stay stable; specific providers may change as we evolve the business.

We do not sell personal data to anyone. We do not share data with advertising networks. We do not use behavioral tracking for advertising purposes.

International data transfers

Some of our service providers are based outside the European Economic Area, primarily in the United States. Where personal data is transferred outside the EEA or the UK, we rely on:

The EU-US Data Privacy Framework where the provider is certified, or
Standard Contractual Clauses approved by the European Commission, supplemented where appropriate by additional safeguards.

You can request more information about a specific transfer by emailing scott@predictablehire.com.

How long we keep your data

Candidate records. We retain your candidate profile for two years from our last meaningful contact with you (a conversation, an active submission, an opportunity you considered). After that point, we either delete your record or contact you to ask whether you want to remain on file. A bulk message you did not engage with does not reset the clock.

Search-specific records. Where you were submitted to a client or considered for a specific search, we retain records relating to that search for at least six months after the search closes, to defend against any potential claim under the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz, AGG) or equivalent legislation.

Client contact records. We retain client contact data for the duration of our relationship and for six years after the last engagement, to comply with German tax, commercial, and civil law retention periods.

Financial and legal records. We retain invoices and contractual documents for ten years, in line with German tax law.

You can ask us to delete your data earlier where no legal obligation prevents us from doing so.

Your rights

Under GDPR (and UK GDPR for UK residents), you have the right to:

Access the personal data we hold about you.
Have inaccurate data corrected.
Have your data deleted in certain circumstances.
Restrict our processing of your data.
Receive your data in a portable format.
Object to processing based on legitimate interest.
Withdraw any consent you have given, at any time.

To exercise any of these rights, email scott@predictablehire.com. We respond within one month. There is no charge for exercising your rights.

Complaints

If you are not happy with how we handle your data, please raise it with us first by emailing scott@predictablehire.com. We will work to resolve it.

You also have the right to complain to a data protection authority:

In Germany, our lead authority is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW). Website: ldi.nrw.de.
In the UK, the Information Commissioner's Office (ICO). Website: ico.org.uk.
In any other EU country, your local supervisory authority.

Cookies and website analytics

Our website (predictablehire.com) is hosted on Wix. When you first visit the site, a cookie consent banner asks you to accept or decline non-essential cookies before they are placed on your device.

Essential cookies. Wix places a small number of cookies that are necessary for the website to function, such as session management and security. These load automatically and do not require your consent.

Analytics cookies. We use Wix's built-in site analytics to understand how visitors use the website, including which pages are visited, time spent on the site, and general traffic patterns. These cookies are only placed if you consent through the cookie banner.

No advertising or tracking cookies. We do not use advertising cookies, retargeting pixels, behavioral tracking, or cross-site profiling.

If we add additional analytics or marketing tools in future, we will update this notice and ensure your consent is obtained before any new non-essential cookies are placed.

You can change your cookie preferences at any time using the cookie settings option on the website.

Google Fonts. Our website uses fonts that are hosted locally by Wix. No data is transmitted to Google's servers when you visit the site.

Changes to this notice

We may update this notice from time to time. The "last updated" date at the top of this page reflects the most recent change. Significant changes will be flagged on this page.