The EU-US Data Privacy Framework, explained for vendor reviews
Solomon Amos · 7 Sep 2026 · 10 min read
Regulatory evidence
Phenom is a global HR technology company that delivers its AI-powered Talent Experience Management (TXM) platform to enterprises, enabling
For each regulation, how many of the requirements it places on your vendors Phenom People Inc. Phenom’s public evidence reaches. Open one for every item with its date and source.
What the vendor lists, typed; public items can be read now, the rest are available on request.
49 documents listed on Phenom People Inc. Phenom’s trust centre
trust.phenom.comAnswers the vendor publishes to questions buyers ask, quoted with the link to where it says so.
Where data is hosted or processed
Where does Phenom store my data?
“Phenom stores data securely on Amazon Web Services (AWS) servers located in Ireland.”
Regions named: Irelandas of 21 Sep 2026Source
Encryption
What encryption standards do you use?
“In Phenom, All data at rest is encrypted using AES-256, and data in transit is encrypted using TLS 1.2 or higher.”
as of 21 Sep 2026Source
Use of customer data to train models
What data sources does Phenom use for training data?
“Phenom uses three kinds of AI models across the platform: 1. Foundational models trained by Phenom (e.g., Fit Score): These are pre-trained without customer data, so that new customers can benefit from our AI “out of the box”. Data sources include job descriptions, and public datasets like O\ NET from the US Department of Labor. 2. Customer-specific models trained by Phenom (e.g., re-ranking models on individual c...”
as of 21 Sep 2026Source
Use of customer data to train models
Are models pre-trained and does Phenom use customer data to train AI for its own purposes?
“Phenom’s AI models are based on pre-trained systems, using foundational models in the way we describe in the answer to the question “What data sources does Phenom use for training data?”. Regarding the use of customer data for Phenom's own purposes: - The Fit Score foundational model is not updated or tuned using customer data. While ongoing customer data may modify inputs to the score, it does not change the core...”
as of 21 Sep 2026Source
Use of customer data to train models
How does Phenom handle PII or sensitive data in training data and what security controls are in place?
“Phenom uses privacy-enhancing technologies for personal identifiable information and does not extract sensitive data for training purposes. Privacy-enhancing technologies include data masking and data aggregation. Both technologies are explained in detail in the Ethical AI Development at Phenom document. Phenom has rigorous security measures implemented on a platform-wide level and Phenom holds a large number of c...”
as of 21 Sep 2026Source
Solomon Amos · 7 Sep 2026 · 10 min read
CertReports Research · 18 Sep 2026 · 12 min read
This maps third-party obligations to the vendor evidence that may support them. It is not legal advice and never a statement that a vendor or its customers comply; confirm scope and sufficiency with your counsel or auditor. “No public evidence” means nothing public was found at the last check. Citations link to the official text.