Segregation of Duties for Candidate ID: Pass-Fail Only

Picture the week before a critical launch. You have five open roles and a hard date. Recruiting is pushing for same-day scheduling, but Legal just flagged that recruiters can currently open raw ID images in a shared vendor portal. Meanwhile Security asks a simple question: "If legal asked you to prove who approved this candidate, can you retrieve it?" This is where segregation of duties stops being a policy memo and becomes an operational control. The failure modes are predictable: - Operational risk: identity review becomes a bottleneck, time-to-offer slips, and delays cluster at moments where identity is unverified. - Legal exposure: recruiters handling raw IDs and biometric artifacts expands the number of people in scope for biometric privacy obligations. If it is not logged, it is not defensible. - Cost of mis-hire: a replacement can cost 50-200% of annual salary depending on role and seniority, and the cost is usually paid in rework and missed delivery, not a clean line item. - Fraud risk: remote hiring pipelines are targeted. Pindrop reports 1 in 6 applicants to remote roles showed signs of fraud in one real-world pipeline. That is not a rounding error. That is a throughput problem and a control problem.

Most hiring stacks were not designed with segregation of duties as a first-class control. The market stitched together point solutions: an ATS here, a background portal there, a video interview tool somewhere else. Each tool solves a local problem and silently expands the blast radius of sensitive data access. Why the market failed to solve this: - Sequential checks slow everything down. Identity verification, interview scheduling, and assessment gating often run as a waterfall workflow. When identity is unresolved, everything waits. - No unified event log. You get screenshots, email threads, and vendor PDFs, not an immutable event log with timestamps and owners. - No evidence packs. Even when a vendor produces an output, it is not anchored to the candidate record with a tamper-resistant chain of custody. - No SLA-bound review queues. Manual review becomes tribal knowledge. There is no alerting when reviews breach a threshold. - Shadow workflows and data silos. Recruiters export IDs "just to move the process forward" and now you have uncontrolled copies, undefined retention, and no audit trail.

Segregation of duties only works if ownership is explicit and the system-of-record is unambiguous. Use this as the minimum viable operating model. Process ownership (who owns what): - Recruiting Ops owns workflow sequencing, SLA targets, and queue management. They decide where the identity gate sits and what downstream steps are blocked until it passes. - Security owns access control, identity policy, exception handling rules, retention controls, and audit export requirements. They decide who can view raw artifacts and for how long. - Hiring Managers own evidence-based scoring discipline. They should never need raw ID data to score capability. They need rubric outputs and assessment evidence. Sources of truth (single source of truth, not "whatever portal has it"): - ATS is the canonical record for candidate stage, disposition, and offer decisions. - Verification service is the canonical record for identity events, but must write back status to the ATS so recruiting can operate without artifact access. - Interview and assessment systems must write back scored evidence and timestamps, not free-text summaries. What is automated vs manually reviewed: - Automated: pass-fail gating, risk-tier assignment, time-stamped status write-backs, evidence pack generation. - Manual: exception review, ambiguous identity cases, and override approvals, all within SLA and with reason codes.

Treat hiring like secure access management. Identity is the gate before access to privileged steps: live interviews, coding environments, and ultimately payroll and system access. An instrumented workflow looks like this: - Identity verification before access. Candidates pass an identity gate before synchronous interviews or assessments that could be proxied. - Event-based triggers. When identity is verified, downstream steps trigger automatically. When it fails or is ambiguous, it routes to a review queue with an SLA. - Automated evidence capture. Every decision produces an evidence pack: timestamps, inputs, outputs, reviewer notes, and reason codes. - Analytics dashboards. Track time-to-event across identity, interview, assessment, offer. Segment by risk tier and by where overrides cluster. - Standardized rubrics. Hiring Manager scoring is stored as structured evidence tied to the candidate record, not as a comment in a calendar invite. This is how you preserve recruiting velocity while shrinking the number of humans who can touch sensitive ID data.

IntegrityLens AI acts as the control plane between Recruiting and Security so you can enforce segregation of duties without slowing the funnel. - Runs biometric identity verification with liveness, face match, and document authentication as an identity gate before privileged steps. - Writes back a simple status to the ATS so recruiters operate on pass-fail and timestamps, not raw artifacts. - Generates immutable evidence packs with time-stamped logs and reviewer notes for audits and incident response. - Supports fraud prevention signals like deepfake and proxy interview detection to reduce downstream interview waste. - Enables privacy-forward handling patterns, including zero-retention biometrics, to reduce the compliance surface area.

Do not do these three things, even if they feel like short-term speed hacks: - Give recruiters raw ID access "just in case". This expands legal exposure and creates uncontrolled copies. - Allow overrides without reason codes and named approvers. A decision without evidence is not audit-ready. - Run identity checks after interviews to avoid friction. You waste interviewer hours on unverified identities and invite proxy behavior upstream.