Privacy Policy – Unsolicited Applications (GDPR)
1. Introduction
This Privacy Policy describes how JWExecutiveSearch processes personal data submitted through unsolicited job applications via our website www.jwexecutivesearch.net (the “Website”), in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable Italian and European data protection laws.
We are committed to protecting the privacy and personal data of all candidates who submit their information to us.
2. Data Controller
The data controller is:
JWExecutiveSearch
Email: [info@jwexecutivesearch.net]
3. Categories of Personal Data Processed
When submitting an unsolicited application, we may process the following personal data:
- Identification and contact details (e.g. name, email address, phone number)
- Professional and employment-related data (e.g. CV, cover letter, work experience, education, qualifications, skills)
- Any additional information voluntarily provided by the candidate
- Technical data related to website usage (e.g. IP address, logs, cookies, where applicable)
Candidates are requested not to include special categories of personal data (such as health data, religious beliefs, political opinions), unless strictly necessary and explicitly required by law.
4. Purpose of Processing
Personal data submitted through unsolicited applications is processed exclusively for the following purposes:
- Evaluating the candidate’s profile for current or future job opportunities
- Managing and storing unsolicited applications in our recruitment database
- Contacting candidates in case of relevant employment opportunities
- Complying with legal and regulatory obligations related to employment and recruitment
5. Legal Basis for Processing
The processing of personal data is based on:
- Article 6(1)(b) GDPR – processing necessary to take steps at the request of the data subject prior to entering into a contract
- Article 6(1)(c) GDPR – compliance with legal obligations
- Article 6(1)(f) GDPR – legitimate interest of the data controller in managing recruitment activities
Where required, processing may also be based on the explicit consent of the data subject.
6. Data Retention Period
Personal data collected through unsolicited applications will be retained for a maximum period of 12 months from the date of submission.
After this period, the data will be securely deleted or anonymized, unless the candidate has provided consent for a longer retention period or a legal obligation requires otherwise.
7. Data Recipients
Personal data may be accessed by:
- Authorized internal personnel involved in recruitment and HR activities
- External service providers (e.g. IT services, hosting providers, recruitment platforms) acting as data processors under Article 28 GDPR
Personal data will not be disclosed to third parties for marketing or commercial purposes.
8. Data Transfers Outside the EU
Personal data is processed within the European Union.
If, in exceptional cases, data is transferred outside the European Economic Area (EEA), such transfers will occur only in compliance with GDPR provisions and with appropriate safeguards in place (e.g. Standard Contractual Clauses).
9. Rights of the Data Subject
In accordance with Articles 15–22 GDPR, candidates have the right to:
- Access their personal data
- Request rectification or erasure of personal data
- Request restriction of processing
- Object to processing based on legitimate interest
- Withdraw consent at any time, where applicable
- Request data portability
- Lodge a complaint with the competent supervisory authority (in Italy: Garante per la Protezione dei Dati Personali)
Requests can be sent to [privacy@email.com].
10. Security Measures
We adopt appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including protection against unauthorized access, loss, misuse, or alteration of personal data.
11. Cookies
For information on the use of cookies and similar technologies, please refer to our Cookie Policy, available on the Website.
12. Updates to This Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in legal or regulatory requirements or in our data processing activities. The updated version will always be published on this page.
13. Contact Details
For any questions regarding this Privacy Policy or the processing of your personal data, please contact:
[privacy@email.com]