Policy Title: Recruiting Confidentiality Policy & Procedure

Effective Date: 01/01/2025
Department: Human Resources

Applies To: All employees, contractors, and third parties involved in the recruitment and hiring process 

1. Purpose

To outline the policies and procedures that govern the protection of confidential information during the recruitment and hiring process at Heichel Plumbing Inc. DBA JMC Concrete Cutting & Demo. This ensures compliance with applicable Florida Statutes, federal labor laws, and internal ethical standards, while safeguarding applicant and corporate data 

2. Policy Statement

All personnel involved in the hiring process must maintain strict confidentiality concerning any information related to applicants, candidates, recruitment strategies, compensation data, and any non-public employment-related discussions. Any breach of confidentiality will result in disciplinary action in accordance with the company’s code of conduct and Florida law. 

3. Scope

This policy applies to:

• Hiring managers
• Superintendents and foremen
• Recruiters (internal and external)
• HR personnel
• Executive leadership
• Any third-party vendors or contractors engaged in recruitment

4. Definitions

• Confidential Information:        Any non-public data related to candidates, hiring strategy, background checks, trade credentials,                                    ,                                                    compensation negotiations, and licensing
• Recipient:                                    Any employee or agent accessing applicant data or participating in hiring
• FCRA:                                           Federal Fair Credit Reporting Act governing   background check handling
• Florida Statute   §542.335:       State law governing enforceability of   non-compete and confidentiality terms

5. Responsibilities

· HR Department: Ensure implementation, training, and monitoring of hiring confidentiality compliance.

· Hiring Managers/Supervisors: Adhere to the policy; sign confidentiality agreements before participating in candidate evaluations.

· Third-Party Recruiters: Required to sign NDAs and follow data security protocols.

· IT/Records: Maintain secure storage and digital encryption of candidate files.

6. Procedures

6.1 Pre-Recruitment

• Draft and post job listings using neutral or blind descriptions where confidentiality is needed (e.g., for replacing current roles).
• Require all participants to sign the Hiring Confidentiality & Non-Disclosure Agreement before accessing candidate materials.

6.2 During Recruitment

• Use encrypted email or a compliant Applicant Tracking System (ATS).
• Avoid candidate discussions in public spaces (trailers, lunch areas, text messages).
• Keep interview notes and scoring metrics digitally or in locked files.
• Do not share resumes or application data with unauthorized personnel.

6.3 Post-Interview & Selection

• Shred all printed resumes/interview sheets within 7 days after position closure.
• Resumes and applications of non-selected candidates will be securely retained for up to 1 year to support future      opportunities and ensure fair recruitment practices.
• Ensure offer letters for sensitive or leadership positions should include appropriate confidentiality or non-disclosure language.
• Securely archive digital records in accordance with FCRA record-keeping laws (minimum of 1 year).
• All recruitment files-whether digital or paper-based-must be stored securely and remain accessible only to authorized personnel.

6.4 Enforcement & Breach Handling

• Any suspected breach must be      reported immediately to the HR Manager/Director.
• Violations will be investigated      and may result in:                    
  1. Formal reprimand
  2. Termination
  3. Legal action (under §542.335, F.S.)
  4. Notification to affected applicants if applicable

7. Recordkeeping

Signed NDAs and confidentiality acknowledgments must be retained for a minimum of 3 years post-hire or after candidate rejection.