Overview
This policy is published by Capifiq Inc. ("Capifiq," "we," "us," or "our") under the Illinois Biometric Information Privacy Act, 740 ILCS 14/15(a), which requires any organization in possession of biometric information to make its retention schedule and destruction guidelines publicly available. We publish it for everyone, not only for candidates in Illinois.
Capifiq operates a meeting platform used by employers to conduct job interviews. Where an interview takes place on the platform, we process the interview recording and related records on the employer's instructions and on the employer's behalf.
This is not a consent form. Where a candidate's interview involves biometric processing that is covered by law, that candidate is asked to sign a separate written release before the interview, and that release is where consent is given. This policy sits alongside it and does not replace it.
What We Treat as Biometric Information
For the purposes of this policy, we treat the following as biometric information, whether or not any measurement is ever derived from it:
- The recording of an interview, which contains the candidate's face and voice.
- Images of a candidate's screen captured during an interview, which can incidentally show a face: in a self-view window, for example.
- Any scan of face geometry or voice geometry derived from either of those, including any transient scan created while checking whether interview video is genuine.
This is deliberately broader than the narrowest reading of the law requires. Some statutes treat a recording as biometric only once a facial or vocal template has actually been extracted from it, and at least one excludes video and audio outright.
We do not rely on that distinction, for a specific reason: an analysis pass can run on a stored interview recording after the interview has finished. A recording that was not biometric at the moment it was made can become the source of a facial or vocal measurement later, while it is still held. Treating the recording as biometric from the outset is the only way to make sure the limits in this policy already applied to it. We would rather govern a recording as biometric and be told it did not have to be, than the reverse.
Who Decides How Long It Is Kept
The employer decides. Each employer using the platform configures how long each category of interview data is kept for its own interviews. That is a decision about the employer's own hiring records, and it is the employer's to make. The allocation of these responsibilities is set out in our Data Processing Agreement and Master Services Agreement with each employer.
Capifiq does not choose an employer's retention periods, does not apply a period of our own in their place, and never extends a period an employer has set.
What we do is enforce the outer limits, in two directions:
- a maximum, where the law of the state a candidate lives in sets one; and
- a minimum for certain records, where deleting too early would destroy a candidate's ability to question a decision made about them.
The period an employer configures applies to an interview as it stood when that interview was arranged. Changing a setting later never reaches an interview that already exists.
The Retention Schedule
Biometric information relating to an interview is permanently destroyed at the earliest of the following:
- when the purpose for holding it has been satisfied;
- at the end of the period the employer has configured for that category, as it stood when the interview was arranged;
- at the end of the maximum period set by the law of the state the candidate lives in, where one applies; or
- in every case, no later than ten years after the interview. No configuration can exceed this.
Whichever of those comes first is the one that applies. A derived measurement is additionally never kept for longer than the recording it was taken from, once the recording is gone, anything calculated from it goes with it.
Maximum Periods Set by Law
Where the state a candidate lives in sets a maximum period for biometric data, that maximum applies to their interview even if the employer has configured a longer one. The shorter period always wins. It is applied automatically when the candidate tells us where they live; the employer does not have to know the rule, and cannot opt out of it.
| Where the candidate lives | Maximum | Basis |
|---|---|---|
| Illinois | 3 years | 740 ILCS 14/15(a): the purpose being satisfied, or 3 years from the last interaction, whichever is first |
| Texas | 1 year | Tex. Bus. & Com. Code §503.001: no later than the first anniversary of the date the purpose ends |
| Washington | No fixed period | RCW 19.375: no longer than reasonably necessary |
| Elsewhere | No fixed period | The employer's own configured period applies, subject to the ten-year limit above |
Where a maximum applies, it reaches the interview recording, the interview audio, images of the candidate's screen, and any measurement derived from them. Where it shortens the audio, the written transcript of that interview is shortened to match, so that a transcript never outlives the recording it was made from.
Minimum Periods We Enforce
A small number of categories cannot be set below a minimum. These are not biometric categories. They exist so that a candidate who wants to question something can still do so, a record destroyed quickly is a record that can no longer be checked, corrected, or disputed, and that works against the candidate rather than for them.
| Category | Minimum |
|---|---|
| Interview audio | 30 days |
| Records of what was observed during the interview | 90 days |
| A candidate's own written work during the interview | 90 days |
| The record of what a candidate was told and agreed to | 1 year |
| The interview record shared with the employer | 7 years |
Interview audio is additionally never kept for a shorter period than the written transcript of the same interview, because the audio is the record and the transcript is only a guide to it.
There is no minimum for interview video, for images of a candidate's screen, or for any derived measurement. An employer may set those as short as it wishes, and the shortest period configured is the one that applies.
How Destruction Happens
When a period elapses, the data in that category is permanently destroyed. Destruction is automatic. Nobody has to request it and nobody has to approve it.
Each category is destroyed on its own schedule rather than all at once, so an interview is progressively thinned rather than deleted in one step. The recording and the images go first; the record of what was decided outlives them. That asymmetry is deliberate. It is what allows the periods on the most sensitive material to be short while a candidate keeps the ability to question an outcome.
Every destruction is recorded: the category, the period that was applied, how much was destroyed, and when. Those records outlive the data they describe, so it remains possible to show that something was destroyed and when.
Where a service provider has received biometric information in order to perform a check, it is required to destroy it within the same period, including any backup copies.
When Destruction Is Paused
Destruction is paused, not cancelled, while either of the following is true:
- a legal hold applies to the interview; or
- a dispute about the interview is open: whether the candidate raised it with us directly or the employer told us the candidate had disputed the outcome.
When the hold is lifted or the dispute is closed, destruction resumes from where it had reached. A paused interview is not excused its retention period, and an interview that was once disputed does not stay frozen after the dispute is resolved.
Records of Consent
The record of what a candidate was told, and what they agreed to, is stored separately from their interview content and is not destroyed as part of a request to delete interview content. This separation is structural rather than procedural: the credentials that can delete interview recordings have no access to the storage that holds the consent record.
This is what allows us to show, years later, what a candidate was actually told, including after their recording has been destroyed.
Finding the Periods for Your Own Interview
Because the employer sets the periods, they differ between employers. The periods that apply to any particular interview are stated in the consent document that candidate is asked to read and sign before the interview, and a copy of that document, including those periods, is available to them afterwards.
That copy is the authoritative statement of what applies to a given interview. This policy describes the framework and the limits; the signed document states the numbers.
Requests and Contact
A candidate may ask for their interview recording and any related biometric data to be deleted. Requests are made to the employer's contact, which is named in the consent document each candidate signs. A request is honoured within 30 days unless a legal obligation or a legal hold requires the data to be kept.
Questions about this policy can be sent to legal@capifiq.ai. For a candidate's wider rights, see Candidate Rights and our Privacy Policy.
Changes to This Policy
A change to this policy applies to interviews arranged after the change takes effect. Interviews that already exist keep the periods they were arranged under, because those periods were stated to the candidate at the time and form part of what that candidate agreed to.
The effective date at the top of this page is updated whenever the policy changes.