Consent and compliance

Recording job interviews in Singapore: the PDPA, evaluative purposes and candidate access

On this page
  1. Singapore's rules at a glance
  2. Is it legal to record a job interview in Singapore?
  3. Should you rely on the evaluative purpose exception or ask for consent?
  4. Can candidates ask for the recording, the transcript or the scorecard?
  5. How long can you keep interview recordings?
  6. What if the tool or the interviewer is outside Singapore?
  7. What does the PDPC say about AI tools?
  8. A consent line for interviews with candidates in Singapore
  9. Checklist before you record interviews in Singapore
  10. Questions people ask

In Singapore, the rule that governs recording a job interview is the Personal Data Protection Act 2012 (PDPA), not a wiretap law: we found no Singapore statute that requires every party's consent before a participant records their own call. The PDPA lets organisations collect personal data without consent for an "evaluative purpose," which includes judging a person's suitability for employment, but section 20 still requires you to tell the candidate the purpose, and the Personal Data Protection Commission (PDPC) treats US-hosted tools as overseas transfers. As of October 2026, the workable practice is to tell candidates you are recording, ask, and keep the recording only as long as the hiring decision needs it.

This page adds Singapore to our country series, which also covers Australia, Canada, Germany and the UK. It is for recruiters, agency consultants and hiring managers who interview candidates located in Singapore by phone or video, including from the US.

This is not legal advice. It summarizes the PDPA and the PDPC's advisory guidelines as published on the linked pages as of October 2026. Advisory guidelines are not legally binding, and the facts of each process matter. Confirm your approach with a Singapore data protection lawyer.

Singapore's rules at a glance

QuestionPDPA positionSource
Is consent needed to record?Consent is the default (section 13), but data may be collected without consent for an evaluative purpose, which covers suitability for employmentPDPC Key Concepts guidelines
Must the candidate be told?Yes: purposes on or before collection (section 20(1)); for employment-related collection, the purpose even where consent is not required (sections 20(4) and (5))PDPA, s.20
Can the candidate get a copy?Yes, of personal data about them (section 21), but opinion data kept solely for an evaluative purpose is excepted (Fifth Schedule)PDPA, s.21; PDPC guidelines para 15.30
How long can you keep it?Until the purpose is no longer served and retention is not needed for legal or business purposes (section 25)PDPC guidelines, chapter 18
Can it go to a US vendor?Only with protection to a standard comparable with the PDPA (section 26)PDPC guidelines, chapter 19

Yes, if you handle the personal data in the recording the way the PDPA requires. The Act defines an "organisation" broadly, including a body "whether or not formed or recognised under the law of Singapore," so a foreign employer or agency collecting candidate data in Singapore is within its reach. A recording of the interview is personal data about the candidate, and the PDPC's guidance lists "recording" as a form of processing.

The consent question has a Singapore-specific answer. The PDPA defines "evaluative purpose" to include "determining the suitability, eligibility or qualifications of the individual ... for employment or for appointment to office." The PDPC's Advisory Guidelines on Key Concepts in the PDPA (revised April 29, 2026) list evaluative purposes among the specific legitimate-interest exceptions in Part 3 of the First Schedule, which allow collection, use and disclosure without consent. So an organisation can argue it does not need consent to record an interview it uses to assess the candidate.

That is not the same as recording silently. The guidelines quote sections 20(4) and (5): on or before collecting, using or disclosing personal data "for the purpose of entering into an employment relationship," an organisation must inform the individual of that purpose and, on request, give the business contact details of someone who can answer questions. And if you rely on consent instead, section 20(1) requires you to state the purposes on or before collection. Either route ends in the same place: tell the candidate you are recording and why before you start.

Should you rely on the evaluative purpose exception or ask for consent?

Asking is usually the better choice for recruiters, for three reasons:

  • The exception covers the evaluation, not everything you might do with the recording. Sharing clips with a client, adding the candidate to a talent pool, or letting a vendor train its models are different purposes.
  • Your process probably spans countries. A consent question works for a candidate in Singapore, an all-party consent US state and the Philippines, where recording without every party's authorization is a crime.
  • It is easy to prove. A spoken yes at the start of the call, noted in your system, answers any later question about what the candidate knew.

Can candidates ask for the recording, the transcript or the scorecard?

Section 21(1) of the PDPA requires an organisation, on request, to provide "as soon as reasonably possible" the personal data about the individual in its possession or control, and information about how it "has been or may have been used or disclosed ... within a year before the date of the request." Section 21(2) says the organisation is not required to provide data in respect of the matters in the Fifth Schedule, and the PDPC's guidelines (paragraph 15.30) list the first of those as "opinion data kept solely for an evaluative purpose."

For interviews, that splits the record in two. The candidate's own recorded answers and the transcript of them are personal data you would normally provide. Interviewers' ratings, comments and recommendations about the candidate are opinion data, and if you keep them solely to evaluate suitability, you may decline to provide them. Section 21(3) also bars disclosure that would reveal personal data about another individual, and section 21(5) then requires you to provide what you can with that part removed. Correction requests have a parallel rule: section 22(6) says an organisation is not required to correct an opinion, and the Sixth Schedule excludes opinion data kept solely for an evaluative purpose (guidelines, paragraph 15.51), so a candidate cannot insist that an interviewer's rating be changed. Our candidate data access requests guide has a handling workflow.

How long can you keep interview recordings?

The PDPA sets no number. Section 25 requires an organisation to stop retaining personal data, or anonymise it, "as soon as it is reasonable to assume" the purpose is no longer served and retention is "no longer necessary for legal or business purposes." The PDPC's guidelines (paragraph 18.2) say the obligation "does not specify a fixed duration" and is judged on "a standard of reasonableness." A defensible approach is a fixed period after the hiring decision, long enough to answer questions or complaints, then deletion. Keeping recordings longer for a talent pool is a new purpose: tell the candidate and ask. Our retention policy template gives the structure.

What if the tool or the interviewer is outside Singapore?

Section 26 bars transfers of personal data outside Singapore except in accordance with the Act's requirements. The PDPC's guidelines explain that the transferring organisation must ensure the data "is protected to a standard comparable with the Data Protection Provisions," and they use a familiar example: a company using "a CRM cloud service that is offered by a service provider from the US" must make sure the provider can protect the data. The organisation stays responsible for the transfer even when a vendor in Singapore moves the data overseas on its behalf.

Two practical points follow. First, a transcription or AI note-taking vendor that processes recordings on your behalf under a written contract is a "data intermediary," subject only to the protection, retention and breach-notification obligations; you keep the rest. Second, if the vendor uses recordings for its own purposes, such as training its models, it is no longer acting only for you, and your notice should say so. If you are a US interviewer, your own state's law also governs your side of the call; see two-party consent states.

What does the PDPC say about AI tools?

The PDPC's Advisory Guidelines on use of Personal Data in AI Recommendation and Decision Systems (issued March 1, 2024) cover systems that recommend or decide, and give "internal HR systems used to recommend potential job candidates" as an example. They encourage organisations to tell people the function that uses their data, the types of data, how the processing is relevant to the feature, and which features of the data are more likely to influence the result, in proportion to the risk. For an interview tool that scores or summarizes candidates, a short line in the notice ("our software produces a transcript and draft notes that an interviewer reviews") goes most of the way.

Interview Signal, for example, shows a read-aloud consent line and has a one-click pause, captures audio from the interviewer's own computer with no bot in the call, and does not retain audio after transcription; the transcript is still personal data and the rules above still apply. For the general questions to ask any vendor, see is it legal to use AI note takers in interviews.

"Before we start: I'd like to record and transcribe this call so I can
give you my full attention and keep an accurate record for assessing
your application. It's used only for this hiring process and deleted
[period] after a decision. If you have questions about how we handle
it, [name/role] can help at [email]. Are you okay with that? You can
say no or ask me to stop at any time; it won't affect your application."

The contact line reflects section 20(5). More wording options are in the interview recording consent script.

Checklist before you record interviews in Singapore

  • Purpose stated to the candidate before recording starts, with a contact for questions.
  • Consent asked and noted, or your reliance on the evaluative purpose exception documented and limited to evaluation.
  • Separate permission for any other use: client clips, talent pool, vendor model training.
  • Access process that separates the candidate's own words (provide) from evaluative opinions (may withhold).
  • Retention period set and documented; deletion scheduled.
  • Due diligence and contract terms for any overseas vendor, meeting the comparable-standard test.

Also interviewing in the region? See India, the Philippines, Japan and New Zealand.

Questions people ask

Do I need a candidate's consent to record a job interview in Singapore?

The PDPA lets organisations collect and use personal data without consent for an evaluative purpose, which includes deciding a person's suitability for employment, but section 20 still requires an organisation to tell the person the purpose when it collects data to enter into an employment relationship. Asking for consent before you record is the simplest way to meet both, and it also covers candidates in places with stricter rules.

Can a candidate in Singapore ask for their interview recording or scorecard?

A candidate can ask for personal data about them and how it was used or disclosed in the past year under section 21 of the PDPA. The Fifth Schedule lets an organisation decline to provide opinion data kept solely for an evaluative purpose, which can cover interviewers' assessments, but the candidate's own recorded answers are not opinion data.

Can I use a US-hosted AI note taker for interviews with candidates in Singapore?

Yes, but the transfer limitation obligation applies. PDPC guidance uses a US-hosted cloud service as its example: the organisation must ensure the provider protects the transferred data to a standard comparable with the PDPA, usually through due diligence and contract terms, even when the provider is only processing on its behalf.

How long can a Singapore employer keep interview recordings?

The PDPA sets no fixed period. Section 25 requires an organisation to stop retaining personal data once the purpose is no longer served and retention is no longer necessary for legal or business purposes, judged on a standard of reasonableness. Set a period tied to the hiring decision and any dispute window, document it, and delete on schedule.