Segregate Duties in Hiring: Pass-Fail Without ID Exposure

You are 48 hours from an offer deadline. A candidate is strong, the hiring manager wants to close, and the recruiter pings: "Verification flagged something. I need to see the ID to decide." If the recruiter can open raw ID artifacts, you have just created a defensibility trap: an untrained reviewer handling sensitive identity data without a policy-backed purpose, and often without a tamper-resistant record of what they saw and why they decided. Operationally, this shows up as SLA breakdown at the worst moment: time-to-offer stalls while people Slack screenshots and interpretations. Legally, it shows up later as "prove who accessed biometric data and why" and you cannot answer from your ATS. Financially, a mis-hire or fraud hire is not just a backfill problem. Role-dependent replacement costs can be 50-200% of annual salary, and the hiring team pays the cycle-time twice. Fraud risk is not theoretical in remote hiring. Checkr reports 31% of hiring managers say they have interviewed a candidate who later turned out to be using a false identity. If your control design forces recruiters to interpret raw ID data under time pressure, you will create both fraud exposure and audit liability.

Recommendation: do not try to solve this with "permissions" bolted onto disconnected tools. The market failed here because most hiring stacks were not built as instrumented, evidence-based workflows. Why it breaks in practice: ATS platforms optimize for candidate movement, not identity gating. Background check vendors optimize for post-offer checks, not pre-interview access control. Coding and interview vendors optimize for assessments, not chain-of-custody of identity artifacts. The result is predictable: - Sequential checks instead of parallelized checks. Verification becomes a late-stage bottleneck and people bypass it to hit offer timelines. - No immutable event log across tools. You cannot reconstruct who saw what, when, under what policy. - No unified evidence packs. Screenshots and email threads become the record, which is not audit-ready. - No SLAs or review queues. Manual review happens in DMs, not in a tracked, SLA-bound queue with accountable owners. - No standardized rubric storage tied to identity outcomes. Hiring managers score in one place, identity decisions happen elsewhere, and Legal gets two conflicting narratives. When leaders say "we have SSO and role permissions," ask the operator question: If Legal asked you to prove who approved this candidate, can you retrieve it? If it is not logged, it is not defensible.

Recommendation: separate workflow ownership from sensitive data ownership. Recruiting Ops should own throughput and stage transitions. Security should own raw identity artifact access policy and exceptions. Hiring Managers should own scoring and rubric discipline. Use this matrix to remove ambiguity before you automate anything:

Recommendation: implement identity gating before access, then run the rest of the funnel as an instrumented workflow with event-based triggers and standardized evidence capture. The model is simple: This is segregation of duties in practice: recruiters manage flow using outcomes; Security manages access to sensitive identity artifacts; the system produces an ATS-anchored audit trail.

IntegrityLens is used as the identity gate and evidence layer that sits between Recruiting Ops and Security, so recruiters can move fast without touching raw ID data. - Runs biometric identity verification (liveness, face match, document authentication) before interviews or assessments. - Enforces role-based views so Recruiting Ops sees pass-fail and reason codes, while Security controls raw artifact access. - Produces immutable evidence packs with timestamped logs and reviewer notes for audit-ready retrieval. - Supports fraud prevention signals (deepfake and proxy interview detection, behavioral signals) to drive step-up verification. - Uses zero-retention biometrics architecture to reduce unnecessary biometric storage exposure while maintaining audit defensibility.

Do not do the following, even if it feels faster in the moment: - Let recruiters download, screenshot, or forward raw ID artifacts to "get a second opinion." This creates uncontrolled copies and breaks chain of custody. - Allow hiring managers to override identity outcomes because "the interview went well." A decision without evidence is not audit-ready. - Route verification exceptions through chat. Manual review without evidence creates audit liabilities and encourages inconsistent standards.

Recommendation: implement a risk-tiered funnel with explicit SLAs, owners, and logged evidence at each step. The goal is to keep time-to-offer bounded while making every exception defensible. Below is a practical sequence you can run tomorrow. Tune the SLA numbers to your volumes and time zones, but do not skip the logging requirements.

Recommendation: implement segregation of duties as a policy with enforcement points, not as a training memo. You are optimizing for reduced time-to-hire, defensible decisions, lower fraud exposure, and standardized scoring across teams. Use this checklist to launch a first version in one sprint: