# How recruitment agencies can sell data to AI companies

URL: https://sellmydatatoai.net/sell-your-data/recruitment-agencies

Recruitment agencies can license job descriptions, de-identified shortlisting decisions, interview feedback and placement outcomes to AI companies, but candidates' resumes and background checks need far more care. Background reports are consumer reports under the FCRA, usable only for permissible purposes, and the CCPA has covered California job applicants' data since 2023. Buyers building hiring tools also face bias audit rules.

## Key takeaways

- AI buyers most want these records from recruitment agencies: (1) job descriptions and role briefs, with client names removed, (2) shortlisting decisions and the reasons recorded and (3) interview feedback and assessment notes, de-identified.
- No AI buyer publishes a price range for recruitment agencies yet, so value depends on volume, years of history, structure and how cleanly the rights can be shown.
- Size buyers look for: No recruitment minimum is published. micro1 asks for 30 or more full-time staff, and Handshake AI for 20 or more staff and three years in business.
- The first rights issue to clear: Background check reports are consumer reports, usable only for FCRA permissible purposes under 15 U.S.C. section 1681b. This page covers 5 more.
- Sellers pay nothing to be assessed. We charge a success fee only when a deal completes, and the fee is agreed in writing before we introduce you to any buyer.

## At a glance

- Records buyers ask for: Job descriptions and role briefs, with client names removed; Shortlisting decisions and the reasons recorded; Interview feedback and assessment notes, de-identified; Recruiter and candidate messaging, de-identified; Placement outcomes and retention data in aggregate; Salary benchmarking and market reports you authored
- Why buyers want them: Recruitment records capture how people are matched to roles, from brief to shortlist to placement. Buyers using them for hiring tools face bias audit and high-risk AI rules, so they need clear provenance.
- Size buyers look for: No recruitment minimum is published. micro1 asks for 30 or more full-time staff, and Handshake AI for 20 or more staff and three years in business.
- Rights issues: Background check reports are consumer reports, usable only for FCRA permissible purposes under 15 U.S.C. section 1681b; The CCPA has covered California job applicants' and employees' data since January 1, 2023; New York City Local Law 144 requires bias audits of automated employment decision tools, raising buyers' provenance demands; Diversity self-identification, health and accommodation records should always be excluded; Client job briefs and fee terms are confidential; UK and EU: Conduct Regulations 2003 regulation 28 for UK work-seekers, and the EU AI Act's high-risk rules for hiring tools

The asset most agencies think of first, the candidate database, is the hardest to license. A resume database is mostly personal information, and background checks are regulated consumer reports. The records that show how recruiters work, from briefs to shortlisting reasons to outcomes, carry far less risk.

## What recruitment data do AI companies buy?

AI companies buy recruitment data that shows matching and judgment. micro1's brief asks for workflows, templates, CRM records and internal communications, and an agency's ATS and CRM hold all of these.

| Record | What it shows | Main issue |
| --- | --- | --- |
| Job descriptions and briefs | How roles are defined | Client confidentiality |
| Shortlisting reasons | How candidates are matched | Candidate identity |
| Interview feedback | How people are assessed | Candidate identity and fairness |
| Recruiter messaging | Candidate and client handling | Personal information throughout |
| Resumes and candidate profiles | Work histories | CCPA and other state privacy laws |
| Background checks and self-identification data | None for licensing | FCRA and sensitive personal information |

## Can recruitment agencies sell candidate resumes?

Recruitment agencies should not sell identifiable candidate resumes. The California Attorney General said in July 2023 that, since January 1, 2023, covered businesses must comply with the CCPA for employee data, and the Act treats a transfer of personal information for monetary or other valuable consideration as a sale.

Your privacy promises to candidates also bind you. The FTC warned in February 2024 that it may be unfair or deceptive to adopt more permissive data practices, such as AI training, through a quiet retroactive change to a privacy policy. Whether [de-identified](https://sellmydatatoai.net/guides/de-identification-for-ai-training-data) records still count as personal information is a question for your lawyer, so take advice before licensing anything derived from candidate files.

## Which candidate data must always be excluded?

Background check reports and self-identification data must always be excluded. Under [15 U.S.C. section 1681b(f)](https://www.law.cornell.edu/uscode/text/15/1681b), a person shall not use or obtain a consumer report for any purpose the Fair Credit Reporting Act does not permit, and a consumer reporting agency may furnish a report for employment purposes only under the conditions in section 1681b(b).

Daniel Goldberg of Frankfurt Kurnit Klein and Selz recommends excluding high-risk data entirely rather than relying on de-identification. For an agency, that means background and criminal record checks, voluntary self-identification forms, work authorization documents and any health or accommodation information.

## Why do AI buyers care about recruitment data provenance?

AI buyers care about recruitment data provenance because hiring tools are regulated. New York City's Local Law 144 bars employers and employment agencies from using an automated employment decision tool unless it has had a bias audit within one year of use, the audit results are public and candidates get notice, and the city began enforcing it on July 5, 2023.

A buyer selling into that market will ask where every record came from, how candidates were told and whether the data reflects biased past decisions. Our [data provenance guide](https://sellmydatatoai.net/guides/data-provenance-explained) explains what they look for.

> **Client briefs are confidential too** Job briefs, fee terms and hiring managers' comments are your clients' confidential information. Remove client names and anything that could identify a role before including briefs.

## If you hold UK or EU data

UK agencies face a sector rule. [Regulation 28 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003](https://www.legislation.gov.uk/uksi/2003/3319/regulation/28) says an agency must not disclose information about a work-seeker without prior consent, except to provide work-finding services, for legal proceedings or to the work-seeker's professional body. The ICO lists diversity data such as ethnic origin and health as special category data.

Buyers serving the EU face the [EU AI Act](https://eur-lex.europa.eu/eli/reg/2024/1689/oj), whose Annex III, point 4 lists AI systems for recruitment or selection as high-risk, and whose Article 10 requires training data governance, including examination for possible biases.

## How do you sell recruitment data through Sell My Data To AI?

We start with a consultation. Our eight-point vetting standard checks contract restrictions, privacy notices and the de-identification method, with a re-identification test run on a sample.

Buyers see redacted samples under a mutual NDA, and you approve every buyer and every license term. Read [whether selling company data to AI is safe](https://sellmydatatoai.net/guides/is-selling-company-data-to-ai-safe), or [book a consultation](https://sellmydatatoai.net/book-a-consultation?side=seller).

## Frequently asked questions

### Is it legal to sell a candidate database to AI companies?

Selling identifiable candidate data to an AI company is hard to square with state privacy law. The CCPA has covered California job applicants' data since January 1, 2023 and treats a transfer for value as a sale, and background reports in the files are FCRA consumer reports. Take independent legal advice, and build any license around de-identified process records.

### Do any buyers publish a price for recruitment data?

No buyer publishes a recruitment-specific price. micro1's general tiers start at $100,000 to $500,000 for a qualified partnership, for companies with 30 or more full-time staff. We tell you in one consultation whether your records are in demand and what a realistic range looks like.

### Can we license job descriptions?

You can usually license job descriptions you wrote once client names and identifying details are removed. Check your terms of business, because some clients treat role briefs and fee terms as confidential. Published job ads are public, so they carry less value than internal briefs and shortlisting notes.

### Does New York City's AI hiring law affect a data sale?

Local Law 144 applies to employers and employment agencies that use automated employment decision tools in New York City, requiring a bias audit within one year of use and notice to candidates. It does not regulate your data sale directly, but it shapes what buyers building hiring tools ask for. Expect detailed questions about provenance.

## Sources

- [15 U.S. Code section 1681b: permissible purposes of consumer reports](https://www.law.cornell.edu/uscode/text/15/1681b), Legal Information Institute, Cornell Law School, accessed November 2026
- [Attorney General Bonta seeks information from California employers on compliance with California Consumer Privacy Act](https://www.oag.ca.gov/news/press-releases/attorney-general-bonta-seeks-information-california-employers-compliance), California Attorney General, accessed November 2026
- [California Civil Code section 1798.140: definitions (CCPA)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1798.140.&lawCode=CIV), California Legislative Information, accessed November 2026
- [AI (and other) companies: quietly changing your terms of service could be unfair or deceptive](https://www.ftc.gov/policy/advocacy-research/tech-at-ftc/2024/02/ai-other-companies-quietly-changing-your-terms-service-could-be-unfair-or-deceptive), Federal Trade Commission, accessed November 2026
- [Automated employment decision tools (AEDT)](https://www.nyc.gov/site/dca/about/automated-employment-decision-tools.page), NYC Department of Consumer and Worker Protection, accessed November 2026
- [Selling company data for AI training: what to know before you say yes](https://technologylaw.fkks.com/post/102o455/selling-company-data-for-ai-training-what-to-know-before-you-say-yes), Frankfurt Kurnit Klein and Selz (Daniel Goldberg), accessed November 2026
- [Monetize your company's operational data](https://www.micro1.ai/data), micro1, accessed November 2026
- [How to sell company data to AI companies (2026 guide)](https://ddiy.co/sell-company-data-to-ai/), ddiy.co, accessed November 2026
- [The Conduct of Employment Agencies and Employment Businesses Regulations 2003, regulation 28](https://www.legislation.gov.uk/uksi/2003/3319/regulation/28), legislation.gov.uk, accessed November 2026
- [What is special category data?](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/special-category-data/what-is-special-category-data/), Information Commissioner's Office, accessed November 2026
- [Regulation (EU) 2024/1689 (Artificial Intelligence Act)](https://eur-lex.europa.eu/eli/reg/2024/1689/oj), EUR-Lex, accessed November 2026

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