Templates

Interview recording policy template: consent, storage, access and retention

On this page
  1. What do you need to decide before writing the policy?
  2. The interview recording policy template
  3. Which laws does each clause answer to?
  4. How do you fill in Appendix A, the approved tools?
  5. Can recordings be used for interviewer training or transcript search?
  6. What about the interviewers being recorded?
  7. How long should each type of record be kept?
  8. How do you roll the policy out and check it is followed?
  9. Questions people ask

An interview recording policy sets out when interviews may be recorded or transcribed, how candidates and interviewers are told and asked, what happens when someone declines, which tools are approved, where recordings and transcripts are stored and who may open them, what else they may be used for, and when they are deleted. Below is a copy-ready policy, the eight decisions to make before you adopt it, and a table of the laws behind each clause: the federal one-party rule, all-party consent states such as California, Illinois's AI video interview and biometric laws, and UK and EU data protection, as of October 2026.

For the words an interviewer says at the start of a call, use the interview recording consent script. This page is the policy those words sit inside.

Not legal advice. Recording law varies by state and country and changes. The statutes linked below are summarized as of October 2026. Have counsel review the policy for the places you hire before you adopt it.

What do you need to decide before writing the policy?

DecisionOptionsA sensible default
What is capturedVideo and audio; audio; transcript only; handwritten notes onlyTranscript only, unless there is a specific reason for audio or video. It meets the accuracy purpose with less data
Consent modelAsk by jurisdiction; ask everyone, everywhereAsk everyone. It costs one sentence and removes the need to know where each person is sitting
When candidates are toldIn the invite; at the start of the call; bothBoth: in writing in the invite, and spoken before capture starts
If a candidate declinesReschedule; proceed without captureProceed without capture, take notes by hand, no effect on the assessment
Which interviewsAll; screens only; by roleAll interviews for a role, or none, so candidates are compared on the same kind of record
Secondary usesHiring decision only; plus training, calibration, searchHiring decision only by default; anything else needs its own notice
RetentionSame for all; by data typeBy type: shortest for audio and video, longer for transcripts and scorecards
Who owns itTA, HR, legal, privacyOne named owner, with legal sign-off

The interview recording policy template

Copy it into your own document and replace everything in square brackets.

INTERVIEW RECORDING AND TRANSCRIPTION POLICY
[Organization]     Version [x]     Effective [date]
Owner: [name, role]     Legal review: [date]     Next review: [date]

1. SCOPE AND DEFINITIONS
1.1 This policy applies to phone screens, video interviews, in-person
    interviews, panel interviews and debriefs conducted by [our staff /
    our consultants / hiring managers at our clients].
1.2 "Capture" means any audio or video recording, any live or
    after-the-fact transcription, and any AI-generated notes or
    summaries made from the conversation.

2. WHAT MAY BE CAPTURED
2.1 Interviews may be [transcribed / audio recorded / video recorded]
    using approved tools only (Appendix A).
2.2 [Video is not recorded.] [Audio is not kept after transcription.]
2.3 Capture is used for every interview for a role, or for none, so
    candidates are assessed on the same kind of record.

3. NOTICE AND CONSENT
3.1 The interview invitation states that the interview will be
    [transcribed / recorded], why, who will see it, how long it is
    kept, and that the candidate can decline without affecting their
    application.
3.2 Before capture starts, the interviewer reads the approved consent
    line and waits for a clear yes:
    "[approved consent line]"
3.3 Consent is asked of every candidate, wherever they are located.
3.4 Interviewers and panelists are told in this policy and in each
    calendar invite that interviews are captured. [Employees
    acknowledge this policy before their first captured interview.]
3.5 If anyone joins mid-call, the interviewer pauses capture and
    repeats the notice.

4. IF SOMEONE DECLINES OR CHANGES THEIR MIND
4.1 The interviewer stops capture immediately, continues the
    interview with handwritten notes, and records only that capture
    was declined.
4.2 Declining has no effect on the assessment. It is not noted in the
    scorecard or mentioned to the hiring manager.
4.3 A candidate may ask for capture to pause during part of the
    interview, for example while discussing an accommodation.

5. APPROVED TOOLS
5.1 Only the tools in Appendix A may be used. Personal accounts, phone
    voice memos and unapproved AI note takers are not permitted.
5.2 A tool is approved only after privacy and security review and a
    signed data processing agreement.
5.3 Tools that analyze facial expression, voice tone or emotion, or
    that infer personality or protected characteristics, are not
    approved.

6. STORAGE AND ACCESS
6.1 Recordings and transcripts are stored in [system / the
    interviewer's managed device] and nowhere else. They are not
    downloaded to personal devices or attached to emails.
6.2 Access is limited to the interviewer, the recruiter on the
    requisition and [the hiring manager]. [Clients receive scorecards
    and submittals, not recordings or transcripts.]
6.3 Access is logged where the system allows.

7. PERMITTED USES
7.1 Captured interviews are used to assess the candidate for the role
    they applied for and to keep an accurate record of the interview.
7.2 Any other use needs prior approval by [owner] and a notice to the
    candidate that names it, including:
    a) interviewer training or calibration (prefer short excerpts;
       whole recordings only where the candidate agreed);
    b) searching across transcripts (see 7.3);
    c) sharing outside the organization.
7.3 Searches across transcripts are limited to job-related questions.
    No searches about health, disability, pregnancy or family plans,
    religion, age, ethnicity, sexual orientation or other protected
    characteristics.

8. RETENTION AND DELETION
8.1 Audio and video: deleted [x days] after the interview, or once the
    transcript is checked, whichever is sooner.
8.2 Transcripts, notes and scorecards: kept for [period], per the
    candidate data retention policy.
8.3 Deletion covers every copy, including local and exported files.
8.4 Legal hold: if a claim, charge or investigation is reasonably
    expected, deletion stops for the affected records until [legal]
    releases the hold.

9. CANDIDATE REQUESTS
9.1 Requests to access, copy or delete a recording or transcript go
    to [contact] and are answered within [the legal deadline].
9.2 Where a law requires deletion on request within a set period,
    that period applies (Appendix B).

10. WHEN A CANDIDATE RECORDS THE INTERVIEW
10.1 If a candidate says they are recording or using an AI note
     taker, the interviewer [continues / asks them to stop / consults
     the recruiter], and notes it in the file.

11. BREACHES AND REVIEW
11.1 Lost devices, misdirected recordings or unauthorized access are
     reported to [owner] within [24 hours].
11.2 This policy is reviewed every [12] months and whenever a tool,
     vendor feature or applicable law changes.

APPENDIX A: Approved tools, what each captures, where data is stored
APPENDIX B: Jurisdiction notes

Which laws does each clause answer to?

ClauseLawWhat it requires
3, consentFederal Wiretap Act, 18 U.S.C. § 2511(2)(d)One-party consent: a party to the conversation may record it, unless for a criminal or tortious purpose
3, consentCalifornia Penal Code § 632, Illinois 720 ILCS 5/14-2, Washington RCW 9.73.030 and other all-party statesConsent of all parties to record a private or confidential conversation. The state list and cross-border rules are in two-party consent states
5.3, 9.2Illinois Artificial Intelligence Video Interview Act, 820 ILCS 42Where AI analyzes applicant-submitted video interviews: notice, an explanation of how the AI works, consent, limits on sharing, and deletion within 30 days of a request; see the Illinois guide
5.3Illinois Biometric Information Privacy Act, 740 ILCS 14Written notice and release before collecting biometric identifiers such as voiceprints; see BIPA and hiring tools
3.1, 7, 8UK GDPR and EU GDPRA lawful basis (usually legitimate interests), notice before capture, purpose limits for new uses, a stated retention period; see recording interviews under UK GDPR
3.1, 8California Consumer Privacy ActA notice at collection naming audio and electronic information and its retention period; see CCPA and applicant data
8.2Title VII recordkeeping, 29 C.F.R. § 1602.14Keep hiring records for one year from the record or the action, longer if a charge is filed

The federal floor is the least of it. The practical rule in clause 3.3, asking everyone, exists because a recruiter rarely knows for certain which state a candidate is calling from, and courts have applied the stricter state's law to calls that cross state lines; see recording calls across state lines.

How do you fill in Appendix A, the approved tools?

List what each tool actually keeps, not what it is called. "AI note taker" covers products that store full video in a vendor's cloud and products that keep only text on the interviewer's laptop. For each tool, record:

  • what it captures (video, audio, transcript, AI notes) and whether a bot joins the meeting;
  • where each item is stored, for how long by default, and whether retention can be shortened;
  • whether the vendor or its sub-processors use your interview data to train models;
  • whether it scores or analyzes candidates, which brings in AI hiring laws as well as recording law; and
  • how you delete one candidate's data on request.

For example, Interview Signal, which we make, captures audio from the interviewer's own computer with no bot in the call, keeps transcripts and notes on that computer, sends audio in short chunks to a speech-to-text provider during the call without retaining it, and does not record video. A video platform's cloud recording sits at the other end of the range. The retention settings for one common platform are in Zoom recording retention settings.

Can recordings be used for interviewer training or transcript search?

Both are legitimate goals, and both are new purposes. A candidate who agreed to be transcribed so you could assess them did not agree to be a teaching example for every new hiring manager. Treat them as separate decisions:

  • Training and calibration. Name the use in the invite, explain who sees it and for how long, and let candidates decline. Short excerpts of the interviewer's question and the answer usually teach more than a whole recording, with less exposure.
  • Search across transcripts. Access controls decide who can open a record; they do not decide what someone asks of a thousand records at once. Clause 7.3 bans searches about protected characteristics, because a pattern found that way is evidence of the discrimination you are trying to avoid.
  • Sharing outside the organization. Agency clients normally need the scorecard and submittal, not the recording. If a client asks for recordings, that is a new disclosure the candidate should hear about first.

What about the interviewers being recorded?

Every captured interview records your own people too. In all-party consent states their consent matters as much as the candidate's, and in the UK and EU their data is personal data with its own notice requirements. Clause 3.4 handles this with a policy acknowledgment and a line in calendar invites. In some EU countries, introducing recording or transcription tools for employees may require consulting a works council first; check before rollout. If transcripts will ever be used to assess interviewers, say so in the policy, because that is a form of monitoring.

How long should each type of record be kept?

RecordTypical approachConstraint
VideoDo not capture, or delete within daysHighest sensitivity; rarely needed for the decision
AudioDelete once the transcript is checkedVoiceprint concerns under biometric laws; little added value after transcription
Transcript and AI notesSame period as scorecardsAt least one year under 29 C.F.R. § 1602.14 for covered US employers; four years for employment records in California
Scorecards and decisionsPer your retention scheduleThe record you will rely on to defend a decision

The full schedule, including state and UK periods, is in how long to keep interview notes.

How do you roll the policy out and check it is followed?

  • Update interview invitation templates and calendar invites with the clause 3.1 wording.
  • Give interviewers the consent line on a card or in the tool, and practice the decline path once.
  • Turn off recording features in platforms you have not approved, at the admin level where possible.
  • Set retention in each tool to match clause 8, rather than relying on manual deletion.
  • Each quarter, sample five interviews: was the notice in the invite, was consent captured, is anything older than the retention period still stored?

Questions people ask

What should an interview recording policy include?

When interviews may be recorded or transcribed, how candidates and interviewers are told and asked, what happens if someone declines, which tools are approved, where recordings and transcripts are stored and who can open them, what else they may be used for, how long they are kept, how candidate requests are handled, and who owns the policy.

Do we need candidate consent to record a job interview?

It depends on where each person is. Federal law and many states allow recording with one party's consent, but California and several other states require every party's consent for confidential conversations, and the stricter rule is the safe one for calls across state lines. A policy that asks every candidate, everywhere, avoids tracking each state.

Can we use interview recordings to train interviewers?

Only if candidates were told about that use. Training is a different purpose from assessing the candidate, so a notice that covers only the hiring decision does not stretch to it. Tell candidates about training use separately, let them decline without affecting their application, and prefer short excerpts to whole recordings.

How long should interview recordings be kept?

Long enough to meet recordkeeping rules and defend a decision, and no longer. US employers covered by Title VII keep hiring records for at least one year, California requires four years for employment records under its 2025 automated-decision rules, and UK and EU law requires a stated period tied to the purpose. Many teams keep transcripts and delete audio and video sooner.