[hollandia]

The recruiter might not be from the same company and creating/sharing these kind of databases with everyone and their mother seems like a hell from the data protection/privacy standpoint.

Feels like an edge case that it's not worth fixing. How often is this going to happen? Do you really want to collect tons of personal data from your candidates before they even show to an interview? Is it worth it to keep personal data of your ex-employees just because of this and is it even legal? (might not be in EU)

[7steps2much]

You can definitely keep your ex-employee's names on file for a couple of years in the EU. Sometimes you might even be legally required to depending on what field you work in, or because you must document just exactly who did something.

That said, sharing it with a recruiter is very likely a big no go. Even sharing it with HR might be sketchy if you are allowed to keep it only for other purposes.

As for collecting data from your candidates, I am pretty sure that you can gather enough to make them uniquely identifiable (name, birthdate, etc.) without any troubles.