Consulting and recruiting
Bullhorn at a staffing firm closure: candidate data you must delete or keep
By SourceX Editorial · Reviewed by Noah Loul ·
Short answer
When a staffing agency is closing, export candidate data from Bullhorn in full before access ends, then sort it into three groups: records kept for legal and tax duties, records deleted, and work records that may be licensed only after candidate identities are removed. In a SourceX transaction, candidate personal information is never licensed raw.
Key takeaways
- Export before you cancel, because a complete copy after access ends depends on your contract and the vendor.
- Payroll and tax records for temporary employees have their own minimum periods, including at least four years for employment tax records under IRS guidance.
- Profiles of candidates who were never submitted are usually the first records to delete once legal holds are cleared.
- Job orders, submission stages and placement outcomes can keep their value after names, contact details and identifying text are removed.
What happens to candidate data when a staffing firm closes?#
Candidate data does not disappear when a staffing firm closes; the company, its officers or a designated custodian stay responsible for it until it is lawfully deleted or transferred. Bullhorn usually holds most of it: candidate profiles, resumes, notes, submissions, placements, client contacts, and the emails and texts recruiters logged against records.
The closure plan should name one person who controls the Bullhorn export, the archive and the deletion schedule. Without that person, records end up scattered across recruiters' laptops, personal inboxes and the shared drive, which makes them harder to secure and harder to delete.
Closing also changes the risk profile. A dormant database with no one watching it is an easy breach target, and the firm's insurance and IT support may end before the data does.
Export Bullhorn before access ends#
Exporting before access ends is the step that cannot be redone later. Read the Bullhorn order form and terms for what happens to data at termination, and raise a full export with your account manager early, because notice periods and retrieval windows are set by contract.
Bullhorn's knowledge base for Bullhorn Automation describes exporting candidate, sales contact or company records to CSV from a saved list or custom search, with export limited to admins. A CSV per entity is a start, but it rarely carries attachments, full note history or the links between records.
- List every record type in use: candidates, contacts, companies, job orders, submissions, placements, notes, tasks, appointments and files.
- Request a full database export with attachments, or plan API extraction with your technical lead.
- Export payroll and back-office data separately if timesheets and pay ran in another system.
- Reconcile record counts in the export against Bullhorn before cancelling.
- Store the archive encrypted, with access limited to the custodian and counsel.
- 01Your work records
- 02Personal details removed
- 03You approve the release
- 04Licensed to AI developers
Keep, delete or license-eligible: sorting the records#
Sorting records into keep, delete and license-eligible groups turns a vague obligation into a schedule. The default actions below are a starting point; retention periods and exceptions are set with counsel for your states, your clients and any open claims.
| Record | Default action | Why | License-eligible after de-identification? |
|---|---|---|---|
| Payroll, timesheets and tax records for temporary employees | Keep | IRS guidance sets at least four years for employment tax records | No |
| Form I-9 and onboarding documents | Keep for the required period, then destroy | Immigration and employment rules set their own periods | No |
| Applications and resumes of submitted candidates | Keep for the recordkeeping period, then delete | Anti-discrimination recordkeeping and possible claims | Only as skills and stage data |
| Profiles of candidates never submitted | Delete under your policy | No business or legal need once duties end | No |
| Background check reports | Keep only as required, then securely dispose | Consumer report rules restrict use and disposal | No |
| Recruiter notes and messages | Review, then delete most | Often hold personal and sensitive details | Rarely, and only after heavy redaction |
| Job orders and client requirements | Keep per client contracts | Commercial and dispute records | Yes, with client identifiers removed |
| Submission stages and placement outcomes | Keep in de-identified form | Show how work moved, without identities | Yes |
Who has a say in what happens to the data?#
Candidates, clients and regulators all have a say. Candidates saw a privacy notice when they applied or registered, and that notice limits what the firm may do with their information now. For businesses the CCPA covers, California's law has applied to job applicant and employee information since its employment exemptions expired on January 1, 2023, while some other state privacy laws, such as Colorado's, exclude employment-context data. Which laws may apply depends on where candidates live and the firm's size, so confirm with counsel.
Client agreements often require return or destruction of client information when the relationship ends, including job descriptions, rate cards and interview feedback. Open wage claims, discrimination charges or audits trigger legal holds, and a hold overrides any deletion schedule.
Selling or transferring the candidate database to another agency is a separate question from licensing de-identified records. A transfer may require notice or consent and should be checked with counsel against the notices candidates actually received.
Candidate PII is never licensed raw#
Candidate personal information is never licensed raw in a SourceX transaction. Names, contact details, addresses, government IDs, dates of birth, photos, pay history tied to a person and identifying free text are removed before any record is even considered, and what remains can still describe how staffing work happens.
Resumes and recruiter notes are the hardest records to de-identify, because employers, schools, project names and dates together can point to one person. Many firms leave them out entirely rather than attempt redaction at scale.
De-identification has to cover client identity too. Job orders often name the client, the hiring manager and the work site, and those details belong to the client under most staffing agreements.
- Job order fields: title, skills, seniority, region rather than street address, required certifications.
- Stage history: submitted, interviewed, offered, placed or rejected, with coarsened dates.
- Outcome fields: filled or unfilled, assignment completed or ended early, reason codes.
- Skills and experience as structured tags rather than resume text.
Illustrative: an IT staffing firm winds down#
Illustrative: a fictional IT staffing firm is closing after its founder retires. It ran Bullhorn for recruiting and a separate back-office system for temp payroll, and much of its business came through a client's managed service provider program.
The founder names the controller as custodian. The firm requests a full Bullhorn export with attachments, reconciles counts, exports payroll from the back office and holds both in an encrypted archive. Counsel sets periods for payroll, I-9 and applicant records, and profiles of never-submitted candidates are deleted after a legal hold check.
Job orders and placement stage histories are copied into a separate de-identified table before deletion runs. The firm later uses a metadata-only fit check to learn whether that table could be licensed, without sharing a single file.
How SourceX approaches staffing closures#
SourceX approaches staffing closures by putting preservation first: export and secure the records before subscriptions end, then decide what to delete and what to assess. The initial fit check collects only metadata, such as systems, record types and years covered.
If records proceed, the SourceX five-step transaction applies: Supply, Rights, Preparation, Approval and Delivery. Candidate identities are removed in Preparation, the owner or wind-down officer approves each step, and a SourceX Evidence Packet records provenance, licensing rights, permitted use, the privacy record and release authorization.
Frequently asked questions
What if our Bullhorn subscription has already ended?
Contact Bullhorn quickly and ask what data still exists and on what terms it can be retrieved, since post-termination handling is governed by your contract. Meanwhile, gather any exports, reports or synced mailboxes recruiters still hold so they can be secured or deleted under the plan.
Who keeps the records after the company is dissolved?
Name a custodian before dissolution, often a former officer, the wind-down officer or an outside records service. The custodian holds the archive, answers legal requests and carries out the deletion schedule. Record the appointment in the closing resolutions so there is no doubt later.
Do we need to notify candidates that we are closing?
No single rule requires it in every case, but notice may be expected under some state laws, client contracts or your own privacy notice, especially if data moves to another company. A short notice also gives candidates a contact for access or deletion requests. Ask counsel what applies to you.
Should we keep a full copy of the database just in case?
Keeping everything indefinitely raises breach and privacy risk without a matching benefit. Keep what retention rules and legal holds require, delete the rest on schedule, and keep a de-identified copy of work records if they may have analytical or licensing value.
Can departing recruiters take their candidate lists?
Candidate lists belong to the firm, not to individual recruiters, and taking them may breach employment agreements and the firm's privacy commitments. Collect devices, revoke Bullhorn and email access before the last day, and remind departing staff of their confidentiality obligations in writing.
Does the order of shutdown steps matter?
Yes. Export first, reconcile the export, revoke user access, cancel the subscription, and only then run deletions under the schedule. Reversing any of those steps risks losing records the firm must keep, or keeping records it promised to delete.
Sources
- Bullhorn's knowledge base says Bullhorn Automation users can export candidate, sales contact or company records to CSV from a saved list or a custom search, and only admins can run the export. Source
- The IRS says to keep employment tax records for at least 4 years after the date that the tax becomes due or is paid, whichever is later. Source
- The California legislature did not extend the CCPA employee and business-to-business exemptions, so they expired on January 1, 2023. Source
- The Colorado Attorney General states that the Colorado Privacy Act does not cover personal data of individuals acting in a commercial or employment context, such as a job applicant. Source
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