How do you vet candidates before I see them is a question your recruitment supplier will shortly have to answer in writing. From 10 December 2026, Australian Privacy Principle 1.7 requires an organisation to state in its privacy policy which decisions about people are made by a computer program, and what personal information that program uses. The Office of the Australian Information Commissioner released the guidance on 30 September.
Most founders asked that question once, at the start, got a sentence about consultants personally reviewing every application, and stopped asking. Outstaffer sells a pre-screened shortlist on a no placement no fee basis, so take what follows as an interested party arguing its own book.
How do you vet candidates before I see them is now a disclosure, not a reassurance
What exactly goes in the privacy policy?
The OAIC's APP 1 guidelines, updated 30 September 2026, require an entity to publish the kinds of personal information its computer programs use, the kinds of decisions made solely by those programs, and the kinds of decisions where something substantially and directly related to the decision is done by one. The trigger is a decision that "could reasonably be expected to significantly affect the rights or interests of an individual".
A shortlist is a decision about everyone who did not make it.
Until now the screening step was the part of the service nobody could inspect. You got a shortlist, you liked it or you did not, and the reasoning stayed inside somebody else's process along with whatever a model inherited from five years of past hiring. A privacy policy is a public document. It will not tell you whether the screening is good. It will tell you whether a machine did it.
The arithmetic on a step nobody prices
ELMO's 2026 HR Industry Benchmark, run by YouGov across 904 Australian HR professionals in January, puts the average cost to hire at $17,000 AUD and the time to fill a vacant role at 25 days, up from 20 a year earlier. Eighty per cent of those organisations use AI and 93 per cent of their HR teams do. Thirty-two per cent of HR leaders expected AI to change hiring outright. Fifteen per cent say it did.
That sample excludes businesses under 20 staff, so read it as market shape, not your numbers.
What does the vetting step actually cost?
Four hires a year at $17,000 is $68,000 of hiring cost, and at 25 days a vacancy that is 100 days of empty seat across the year, 20 of them added since last year. The screening step is inside that $68,000 and itemised nowhere in it. You are paying for judgement you cannot see, and the timeline the tool was meant to compress got longer.
Vetting candidates before you see them is not automatically caught
Does the obligation reach recruitment screening?
Not cleanly, and anyone telling you otherwise is selling something. The OAIC's examples run to decisions made under legislation, decisions affecting rights under a contract or arrangement, and access to a significant service or support. A candidate has no contract with you. The one employment example in the guidance is an AI tool drafting performance assessments that feed promotion decisions, an existing employee rather than an applicant. Get advice for your own situation.
The honest counter is that this is a wording obligation on a document almost nobody reads, policed by a regulator whose attention has been on data breaches. Fair. Running the search yourself remains the other way to see the reasoning.
Related reading
Ask again, and ask for it in writing
My position is that the deadline matters less than the pressure it creates. For the first time a supplier has an outside reason to describe its screening in plain language. Ask how they vet candidates before you see them, which part of that is a program, and what the program reads. If the answer is a paragraph about consultants, you have learned something.
If you want the version where the screening is described before you buy, sign up and run one role through it. So: when a supplier finally writes down what the machine does, what would make you walk away?
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