KVKK compliant AI interviews

How does KVKK apply to AI interviews?

A KVKK compliant AI interview is a process that, while handling personal data such as recordings, transcripts, and scores, meets the law's principles of notice, lawful basis, purpose limitation, retention, and data-subject rights. In November 2025 the KVKK published its Generative AI and Data Protection Guidelines, stressing transparency, accountability, human oversight, and data minimization.[4] The high-risk classification of hiring AI itself comes from the EU AI Act (Annex III, Section 4), which the KVKK approach broadly aligns with.[5]

Is the voice recording biometric data?

The recording and transcript are personal data but are not automatically special-category biometric data. The line is crossed by voiceprinting that converts a voice into an identity template. Intrvio processes voice to evaluate interview content, not to authenticate identity, and extracts no voiceprint, so processing falls under the general regime, not the Article 6 special-category regime. This distinction directly shapes your lawful basis and risk assessment.[3]

Lawful basis and notice

The most defensible approach in hiring is to rely on performance-of-contract and legitimate-interest bases rather than making explicit consent the sole basis, with a separate, clear notice for the extra voice/video processing. Consent may not count as freely given inside an employment relationship and can be withdrawn at any time. Under Article 10 the candidate must be told the controller, the purpose, transfer recipients, the collection method, the lawful basis, and the Article 11 rights; the use of AI and the human-review path must appear in that notice.[1][2]

Retention and destruction

KVKK forbids keeping data longer than the purpose requires and calls for a retention-and-destruction policy. A short objection window for rejected candidates is typical. But if you screen candidates into the EU, EU AI Act Article 26(6) requires a minimum six-month log retention for high-risk systems, and you must reconcile the two periods in one policy.[1][5]

Candidate rights and automated decisions

Article 11 gives the candidate rights to access, rectify, erase, and object to an adverse outcome produced solely by automated analysis. The final hiring decision must therefore be made by a human and its rationale recorded. In Intrvio, GAIA produces the evaluation but a person makes the decision; AI evidence and human judgment are kept separate, which satisfies both KVKK and EU AI Act human-oversight duties.

How Intrvio helps

• KVKK notice template. Candidate-side 'AI is being used' notice with the lawful basis and a human-review path.
• Human-decision separation. GAIA's score is recorded separately from the human review, defusing any sole-automated-decision claim.
• Audit log. Every session, score, and review action is signed and immutably retained.
• Retention control. Retention windows are configurable per candidate record; KVKK and the EU AI Act six-month log are managed together.
• Region tagging. Every interview record carries an EU or TR region tag, proving data residency in audits.

Responsibility is shared

Let us be plain: Intrvio is a tool, the employer is the data controller of the candidate's data, and this page is not legal advice. Work with your in-house legal team. For more, see our candidate notice, Trust Center, and EU AI Act compliance page. To see the product, visit AI interview platform and AI interviewer.