Effective date: 25-03-2018


1. Introduction

This is the Privacy Statement of HPW Executive Search B.V., having it’s office on the Koninginnegracht 19, 2514 AB The Hague, registered at the Dutch Chamber of Commerce under number 65435532, hereinafter referred to as: “HPW”. HPW is an executive search firm and collects a variety of personal data as defined in the applicable legislation (Personal Data) necessary to provide such services.

This Privacy Statement provides information on the processing of personal data “Personal Data” in the recruitment process of HPW and other related activities. This Privacy Statement may be changed over time. You are advised to regularly review the Privacy Statement for possible changes. This Privacy Statement was last changed on the 25th of March, 2018.

2. When does this privacy statement apply?

This Privacy Statement is applicable to the processing by HPW of all Personal Data with respect to the recruitment process and other related services.

3. Who is responsible for your Personal Data?

HPW and/or its affiliated companies are the controller (verwerkingsverantwoordelijke) for the processing of your Personal Data. This Privacy Statement indicates what Personal Data are processed by HPW and for what purpose, and to which persons or entities the data will or may be provided.

4. For which purposes do we process your Personal Data?

4.1 For recruitment purposes including to inform and communicate with you with regard to your employment, or job application, or with respect to jobs we do think can be interesting for you.

(a) What does this purpose entail?

If you contact one of our recruiters, apply for a vacancy or register at we include the Personal Data you provide us in our recruitment database. Also, we will process your Personal Data to manage our recruitment database. We will propose your Personal Data for recruitment purposes, including without limitation:

  1. Inform you about job opportunities;
  2. Request additional information concerning a new job opportunity and/or assessing your application;
  3. Internal HPW business purposes in the scope of HR recruitment, preparation, development and assessment of recruitment strategies/campaigns;
  4. If hired, HPW will process your information as necessary in relation to your employment and the handling with the client(s) of HPW.

(b) On what legal basis do we process Personal Data for this purpose?

We process your Personal Data for our legitimate interest. HPW is an executive search firm and collects a variety of Personal Data necessary to provide such services. We search and recruit potential candidates for potential employers and clients, so your Personal Data may be used for:

  1. Managing recruitment and resourcing activities, including activities related to organizational planning. In the course of recruitment activities, we may use your information:
    • To set up and conduct interviews and assessments;
    • To evaluate, select and recruit applicants;
    • To conduct background checks and assessments as required or permitted by applicable local law;
    • To contact third party references provided by you to evaluate your previous performances;
    • Or as otherwise necessary in context of recruitment activities.
  2. Development of services: We may use your Personal Data to develop and improve our recruitment processes, websites and other related services. Where feasible, we use aggregated anonymous information in context of the development activities.
  3. Legal and regulatory compliance, including obtaining and releasing your Personal Data as required by law, judicial organizations or practice in order to comply with legal obligations imposed on HPW.

(c) Which Personal Data do we process for this purpose?

For this purpose, we process your Personal Data such as:

your name, street address, telephone number and email address and other contact details, your competences, skills, experience and education, e.g. your curriculum vitae or resume, previous employments, educational details and qualifications, third party references, your preferences, e.g. preferred country of employment, areas of interest as well as your preferred ways to be contacted; as well as your user identity, e.g. user names and other such information used in connection with authenticating you, correspondence with HPW with regard to job applications (including references).

We process your contact details, date of birth, gender, civil status, nationality, photographs, citizen service number, ID card or passport details, declaration of employment status, chamber of commerce and VAT details, recruitment information (such as employment history, education history details), job and position data, work permit details, availability, terms of employment, tax details, payment details, insurance details and location and organizations.

And other information, such as information found from public sources as well as information related to credit or background checks, depending on the position you are applying for, and where necessary for the recruitment activities.

(d) How long do we retain your Personal Data for this purpose?

For this purpose, your Personal Data will be retained for as long as required and depending on local law. Annually, you will be asked by email if your Personal Data are up to date and/or to confirm whether HPW can use your Personal Data for the following year. If you don’t confirm this, your Personal Data will be deleted from our systems.

5. Who has access to your Personal Data?

5.1 Access to your Personal Data within HPW

All HPW employees directly involved in the recruitment phase have access to your data but only to the extent necessary to fulfil their respective tasks.

5.2 Access to your Personal Data by third parties

HPW works with a limited number of clients that process your Personal Data to determine if you fit their company. HPW may share your Personal Data with these clients who will process it exclusively for the purposes described in chapter 4.

The following categories of third parties have access to your Personal Data where relevant for the recruitment process, but not limited: data flow of recruitment process, screening of resumes, set up and conduct job interviews and assessments, evaluate, select and recruit applicants, conduct background checks, contact third party references provided by you to evaluate your previous performances or as otherwise necessary in the context of recruitment activities.

If your Personal Data are transferred to a recipient in a country that does not provide an adequate level of protection of Personal Data, HPW will take measures to ensure that your Personal Data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.

In other cases, your Personal Data will not be supplied to third parties, except when required by law.

5.3 The use of your Personal Data by data processors

When a third party processes your Personal Data solely following HPW's instructions, it acts as a data processor. We enter into an agreement with such a data processor concerning the processing of Personal Data. In this agreement we include, at a minimum, the following obligations to safeguard that your Personal Data are solely provided to the data processor to provide services to us.

6. How are your Personal Data secured?

HPW has taken adequate safeguards to ensure the confidentiality and security of your Personal Data. HPW has implemented appropriate technical, physical and organisational measures to protect Personal Data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing.

7. Questions or requests for access, correction and removal?

You can request access, correction, restriction, portability or removal of the data that HPW processes about you at any time by sending a request to:

Should you have any questions regarding the processing of your Personal Data, please contact

If you feel that we do not comply with the applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.