This page is general information, not legal, tax or financial advice. Talk to a qualified professional about your situation.
A staffing or recruiting firm can consider licensing its own operating records (job orders, placement workflows, recruiter playbooks, internal communication) but should keep background check reports and candidate personal data out. Consumer reports may be used only for the permissible purposes listed in the Fair Credit Reporting Act, such as employment decisions (15 U.S.C. 1681b), and anyone holding consumer report information must dispose of it in a way that guards against unauthorized access (16 CFR 682.3). micro1, Nyne and Troveo publish no industry limits, so staffing firms are routed on size and records.
Records and how they are usually treated
| Records | Usually | Why |
|---|---|---|
| Background check and consumer reports | Exclude, then dispose properly | FCRA permissible purposes; FTC disposal rule |
| Candidate résumés, notes and assessments | Exclude unless a privacy lawyer approves | Personal data collected for recruiting |
| Client job orders and fee agreements | Possible, scrubbed | Client confidentiality clauses may apply |
| Placement workflow and ATS activity history | Possible, after de-identification | Contains candidate personal data |
| Recruiter playbooks, scripts, training | Often possible | Your work product |
| Internal email and chat | Possible, after review | De-identification by the buyer |
Before you apply
- Pull background check data out first, and dispose of what you no longer need under the FTC disposal rule.
- Check your candidate privacy notice and state privacy laws, such as California’s, before any candidate data is in scope.
- Keep required records. EEOC rules require one year of personnel and employment records (29 CFR 1602.14); a licence covers a copy only.
- Read client agreements for confidentiality on job orders and fees.
Which buyers take this industry
| Buyer and program | Industry rule | Company minimums | Operating or closed |
|---|---|---|---|
| micro1: Enterprise Data Partnership | No industry limit in the buyer’s published rules | 30+ full-time employees and substantial historical data; several years of records across systems is a stronger fit. No fixed minimum file count or size. | Both. Operating companies apply to the Enterprise Data Partnership; companies no longer operating apply to the Defunct Company Data Partnership. |
| micro1: Defunct Company Data Partnership | No industry limit in the buyer’s published rules | 30+ full-time employees and substantial historical data; several years of records across systems is a stronger fit. No fixed minimum file count or size. | Both. Operating companies apply to the Enterprise Data Partnership; companies no longer operating apply to the Defunct Company Data Partnership. |
| Nyne: Company data licensing | No industry limit in the buyer’s published rules | 20+ full-time US W-2 employees and 3+ years in business, plus a decision maker who can approve the licence | Operating companies only |
| Mode: Company data partnership | No industry limit in the buyer’s published rules | 10+ employees for legal; 15+ for accounting, medical and finance; 50+ for all other businesses. Several years of records you own make a stronger fit. | Not stated. Mode says businesses and nonprofits can qualify. |
| Troveo: Business data licensing | No industry limit in the buyer’s published rules | Not stated | Not stated |
Questions people ask
Can we license our candidate database?
Treat it as excluded unless a privacy lawyer approves a specific approach. Résumés and candidate notes are personal data collected for recruiting, and your privacy notice and state privacy laws limit other uses.
How long do we keep hiring records?
EEOC rules require employers to keep personnel and employment records for one year from when the record was made or the personnel action was taken, longer if a charge of discrimination is filed. Licensing a copy does not change that.
Sources
- 15 U.S. Code § 1681b: Permissible purposes of consumer reports (Cornell LII)
- 16 CFR § 682.3: Proper disposal of consumer information (Cornell LII)
- 29 CFR § 1602.14: Preservation of records made or kept (Cornell LII)
- Cal. Civ. Code § 1798.140: CCPA definitions (California Privacy Protection Agency, PDF)
- micro1: Monetize your company's operational data