Privacy Policy
Anderson Wise privacy policy
Anderson Wise S.à r.l. will process your personal data in order to carry out its recruitment and executive search activities, namely identifying, qualifying and presenting suitable profiles to its client companies, as well as constituting and managing a pool of candidates.
As a controller processing personal data, Anderson Wise must comply with its obligations as a controller under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data (General Data Protection Regulation).
Please find below the contact details of Anderson Wise:
Anderson Wise S.à r.l.
21, rue Glesener
L-1631 Luxembourg
Tél. : (+352) 24 51 31 88
E-mail : info@andersonwise.com
Website : https://andersonwise.com/
For any questions regarding the processing of your personal data carried out by Anderson Wise, please contact Anderson Wise by:
- Email: privacy@andersonwise.com
- Post: Anderson Wise S.à r.l.
For the attention of the Data Protection Team
21, rue Glesener
L-1631 Luxembourg - Phone: (+352) 24 51 31 88
Personal data processing activities carried out by Anderson Wise in respect of candidates are described below. For each processing activity, detailed information is set out hereunder, including information regarding the exercise of your rights with Anderson Wise.
1. Processing necessary for an assignment to fill a position
Anderson Wise is entrusted by employers (client companies) with assignments to fill a position. In this context, Anderson Wise searches for, identifies, qualifies and presents suitable profiles to the client company, which then makes its own hiring decision. Anderson Wise processes the personal data necessary to carry out such assignments.
1.1 Purposes of the processing
Anderson Wise (21, rue Glesener, L-1631 Luxembourg) processes your personal data in order to carry out a specific recruitment assignment for which your profile is being considered. This includes:
- searching for and identifying potential candidates, including through professional networks (such as LinkedIn) and through job advertisements published on the Anderson Wise website and on other media;
- contacting candidates to present an available job opportunity;
- receiving and reviewing applications submitted in response to a job advertisement;
- assessing and qualifying candidates (skills, experience, motivation and suitability for the position and the client company);
- presenting a selection of the most suitable profiles (shortlist) to the client company so that it can make its hiring decision.
1.2 Personal data processed
The following personal data is collected and accessible by the Anderson Wise staff members in charge of the assignment:
- Identification and contact data: title, name, first name, email address, phone number, and, where applicable, postal address.
- Professional data: curriculum vitae, cover letter, career history, current and past positions and employers, qualifications, diplomas and certifications, languages, professional skills and references.
- Data generated during the process: notes and reports of phone screens and interviews, qualification and evaluation of your application and, where applicable, the results of assessments.
- Source of the profile (for instance: application in response to a job advertisement, professional network, or direct approach).
We recommend mentioning only information that is necessary for the assignment. In particular, sensitive personal data (within the meaning of Article 9 of the General Data Protection Regulation – for instance, data concerning health, or related to political opinions, trade-union membership or religious beliefs) should not be communicated if it is not indispensable.
1.3 Legal basis for the processing
The processing of personal data carried out by Anderson Wise in this context is based on the legitimate interests pursued by Anderson Wise [Article 6, paragraph 1, point f) of the General Data Protection Regulation].
The legitimate interests pursued are the identification, qualification and presentation of suitable candidates to client companies in order to fill the positions entrusted to Anderson Wise, as part of its recruitment and executive search activity.
1.4 Source of the personal data
Your personal data is either provided directly by you (for instance, when you respond to a job advertisement or are in contact with Anderson Wise), or collected from publicly accessible professional sources and networks (such as LinkedIn) when Anderson Wise identifies your profile in the context of an assignment.
1.5 Categories of recipients of the personal data
Within Anderson Wise, the personal data mentioned above can be consulted by the Anderson Wise staff in charge of the assignment (consultants and partners).
The personal data of shortlisted candidates is transmitted to the client company to which the profiles are presented. The client company acts as a separate controller in respect of the processing it carries out for its own recruitment purposes.
The personal data processed can also be accessed by the service providers of Anderson Wise (for instance applicant-tracking and IT hosting providers and, where applicable, assessment-tool providers), acting as processors on behalf of Anderson Wise under Article 28 of the General Data Protection Regulation.
1.6 Storage duration
The personal data processed for a specific assignment is kept for the time necessary to complete that assignment.
Where you are not retained for the position, your data is kept for a period of three (3) months from the closure of the recruitment process, in order to allow Anderson Wise to provide explanations regarding the decision. After this period, your data is deleted, unless it is retained within the candidate pool under the conditions described in section 2 below.
Personal data may, where necessary, be kept in intermediate archiving for evidentiary purposes (in particular to defend against possible claims, including discrimination claims) for a period not exceeding five (5) years from the closure of the recruitment process.
1.7 Rights of the data subject
You have the right to access your personal data and to obtain a copy of it (Article 15 of the General Data Protection Regulation), to obtain the rectification of inaccurate or incomplete personal data (Article 16 of the General Data Protection Regulation), to object to the processing of your personal data under the conditions laid down in Article 21 of the General Data Protection Regulation, to obtain the erasure of your personal data under the conditions laid down in Article 17 of the General Data Protection Regulation, and to obtain the restriction of the processing under the conditions laid down in Article 18 of the General Data Protection Regulation.
For any questions regarding the processing of your personal data carried out by Anderson Wise, and for any queries regarding the exercise of your rights, please contact privacy@andersonwise.com
1.8 Complaint
If you consider that the processing of your personal data by Anderson Wise infringes the General Data Protection Regulation, you can lodge a complaint with the National Commission for Data Protection (Commission nationale pour la protection des données – CNPD).
2. Constitution and management of the candidate pool
Beyond any specific assignment, Anderson Wise constitutes and maintains a pool of candidates in order to contact you in the future regarding job opportunities matching your profile.
2.1 Purposes of the processing
Anderson Wise (21, rue Glesener, L-1631 Luxembourg) processes your personal data in order to constitute and manage a pool of candidates, with a view to contacting you in the future to present job opportunities matching your profile.
2.2 Personal data processed
The following personal data is collected and accessible by the Anderson Wise staff members in charge of the candidate pool:
- Identification and contact data: title, name, first name, email address, phone number, and where applicable postal address.
- Professional data: curriculum vitae, career history, current and past positions and employers, qualifications, diplomas and certifications, languages, professional skills and areas of expertise.
- Source of the profile and a record of your interactions with Anderson Wise (in particular the date of the last contact).
We recommend that only information necessary for this purpose be processed. In particular, sensitive personal data (within the meaning of Article 9 of the General Data Protection Regulation) should not be communicated if it is not indispensable.
2.3 Legal basis for the processing
The processing of personal data carried out by Anderson Wise in this context is based on the legitimate interests pursued by Anderson Wise [Article 6, paragraph 1, point f) of the General Data Protection Regulation].
The legitimate interests pursued are the maintenance of a qualified pool of candidates allowing Anderson Wise to match candidates with suitable job opportunities as part of its recruitment and executive search activity. You may object to this processing at any time under the conditions set out in section 5 below.
2.4 Source of the personal data
Your personal data is either provided directly by you, or collected from publicly accessible professional sources and networks (such as LinkedIn) when Anderson Wise identifies your profile with a view to including it in the candidate pool.
2.5 Objection and removal from the candidate pool
You can object to your presence in the candidate pool at any time, without having to justify your request, by directly contacting Anderson Wise privacy@andersonwise.com. Your personal data is then removed from the candidate pool and deleted within 30 days, unless it needs to be retained for evidentiary purposes.
2.6 Categories of recipients of the personal data
Within Anderson Wise, the personal data mentioned above can be consulted by the Anderson Wise staff in charge of the candidate pool (consultants and partners).
The personal data processed can also be accessed by the service providers of Anderson Wise (for instance applicant-tracking and IT hosting providers), acting as processors on behalf of Anderson Wise under Article 28 of the General Data Protection Regulation.
Where your profile is considered for a specific assignment and presented to a client company, the processing described in section 1 above applies.
2.7 Storage duration
The personal data contained in the candidate pool is kept for a period not exceeding two (2) years from the last contact with you. At the end of this period, your data is deleted, unless Anderson Wise contacts you again and you do not object to the continued retention of your data, in which case the retention period may be renewed for a further period of up to two (2) years.
2.8 Rights of the data subject
You have the right to access your personal data and to obtain a copy of them (Article 15 of the General Data Protection Regulation), to obtain the rectification of inaccurate or incomplete personal data (Article 16 of the General Data Protection Regulation), to object to the processing of your personal data under the conditions laid down in Article 21 of the General Data Protection Regulation, to obtain the erasure of your personal data under the conditions laid down in Article 17 of the General Data Protection Regulation, and to obtain the restriction of the processing under the conditions laid down in Article 18 of the General Data Protection Regulation.
For any questions regarding the processing of your personal data carried out by Anderson Wise, and for any queries regarding the exercise of your rights, please contact privacy@andersonwise.com.
2.9 Complaint
If you consider that the processing of your personal data by Anderson Wise infringes the General Data Protection Regulation, you can lodge a complaint with the National Commission for Data Protection (Commission nationale pour la protection des données – CNPD).