Switching ATS: what to do with old candidate and placement records

What are your options for old ATS records?#

The options for old ATS records come down to four paths: migrate, archive, delete or de-identify. Most staffing firms use all four, applied record family by record family rather than as a single decision for the whole database.

The mistake to avoid is defaulting to migrate everything. A new ATS that inherits every dormant candidate profile also inherits the duty to answer access and deletion requests for those people, along with duplicates and stale contact details that clutter recruiter searches.

Which record families should you separate first?#

The record families to separate first are the ones with different owners and different rules: candidate data, client data and the firm's own process history. Pulling them apart early lets each family get its own decision instead of moving one tangled export.

Tag each family with its source system, date range, owner and any known restriction. That single sheet becomes the map for field mapping, for retention decisions and for any later review by an acquirer or counsel.

• 1Candidate profiles: contact details, work history, skills, source and consent fields.
• 2Attachments: resumes, cover letters, certifications and any identity or work authorization documents.
• 3Recruiter notes and activity: call notes, synced emails, texts and interview feedback logged against a person.
• 4Third-party-sourced records: resumes downloaded from job boards or added by sourcing tools, which may carry their own license terms.
• 5Job orders: client requirements, rates, statuses and close reasons.
• 6Submittals and interviews: who was sent to which order, when, and what the client decided.
• 7Placements: start and end dates, pay and bill rates, extensions, conversions and early ends.
• 8Compliance records: EEO self-identification, background check results and onboarding documents, which often have separate retention rules.

The export deadline is set by the old contract, not by go-live#

The export deadline in an ATS switch is set by the old vendor's post-termination terms. Once the subscription ends, access narrows to whatever the contract allows, and some vendors charge for exports requested late.

Greenhouse is one documented example. Its Master Subscription Agreement says customer data is queued for deletion 90 days after the agreement ends, and if the customer asks within 30 days of termination, Greenhouse can provide an export file at its then-current data migration rates. Its data processing addendum describes personal data being deleted on the same schedule, subject to its backup cycle. Terms change between versions, and newer versions may count the request window differently, so read the agreement you actually signed.

Export tooling also varies. Bullhorn's knowledge base describes CSV exports of candidate, contact or company records from saved lists or searches in Bullhorn Automation, run by admins only, which covers lists rather than a full database with placements. Ask the vendor in writing what a complete export includes: attachments, activity history, custom fields and audit logs.

How retention rules shape what you carry forward#

Retention rules decide which old candidate records you may keep, and therefore which ones are worth migrating at all. A migration is the cheapest moment to apply them, because every record is already being touched.

Privacy law has moved toward applicant data. California's temporary CCPA exemption for employee and business-to-business data expired on January 1, 2023, so applicant records held by covered businesses now sit fully within the law. Other states differ: Colorado's attorney general says the Colorado Privacy Act does not cover people acting in an employment context, such as a job applicant. Which laws reach your records is a question for counsel.

Recordkeeping rules can pull the other way. For staffing firms that employ temporary workers on their own payroll, the Department of Labor's FLSA guidance calls for payroll records to be preserved for at least three years, and records such as time cards for two years. Build a schedule with counsel that names each record family, its keep period and its trigger date, then configure it on day one; Greenhouse, for example, lets site admins set retention rules per office for rejected and hired candidates.

How to keep placement outcomes without candidate identities#

Placement outcomes can usually be kept as de-identified process records: the sequence from job order to submittal to interview to start, with dates and outcome codes but without the person attached. Those records stay useful for branch reporting, forecasting and outside review long after the candidate profiles are gone.

Replace person IDs with a new random key and do not store the lookup table beside the archive. GDPR Recital 26 treats pseudonymised data that can be re-linked with additional information as personal data, and California's deidentified standard requires reasonable safeguards, a public commitment not to re-identify and contractual limits on recipients. Free-text fields need review by a person, not only a pattern-matching tool.

Illustrative: a clerical staffing firm retires a legacy ATS#

Illustrative: a fictional administrative and clerical staffing firm with several branches is moving from an on-premise ATS it has run since its early years to a cloud ATS. The old database holds candidate profiles from every branch, scanned onboarding documents, recruiter notes and a long run of job orders and placements.

The COO's team migrates active candidates, open orders and current assignments only. Closed orders and placements go to a read-only archive with IDs intact, rejected applicants past the counsel-approved retention period are deleted after a legal-hold check, and placement events are also kept as a de-identified table for branch reporting. The cutover plan sets the full export date well before the old maintenance contract ends, and the onboarding scans move to a restricted folder with their own retention date.

How SourceX looks at a retired ATS archive#

SourceX looks at a retired ATS archive through the SourceX five-step transaction: Supply, Rights, Preparation, Approval and Delivery. In staffing, candidate profiles, resumes and recruiter notes are excluded from the start, and the records that can qualify are de-identified job order, submittal and placement events.

The first fit check uses metadata only: system names, years of accessible history and which record families exist. If a package proceeds, the SourceX Evidence Packet records provenance, licensing rights, permitted use, the privacy record and release authorization, and large archives stay in the firm's own storage until it approves delivery.