Privacy Policy

1. Introduction

Welcome to the Osander website (“website”). Osander ApS (“Osander”, “we”, “us” and/or “our”) manages this website to provide our users (“you” and “your”) with information about Osander and its services.

Osander serves the clients (“Clients”) who are interested in Osander’s recruitment & search services and candidates (“Candidates”) who apply for the jobs and/or register their CVs on our website. The Candidates who have passed our in-depth screening process become part of our network and are referred to as “Talent/s”.

The personal data that we receive both from the clients and candidates differ in the way it is being handled. Thus, we outline our data practices below and explain how we store and use your personal data, e.g. whether we are helping you find a job, providing you with executive search services, or you are simply visiting our website.

We elaborate on how we protect and safeguard the information we collect from you, and it is your guarantee that we comply with legal obligations when we process and use your personal data. The Privacy Policy applies to Website Users, Prospective Candidates, Talents, Clients, as well as the people we reach out to during the process of reference taking. To ensure that we remain compliant when processing your personal data, we may adjust the Privacy Policy from time to time. Whenever amendments are made, we will adjust the date for ‘last updated’ at the bottom of the page.

2. Scope

This Privacy Policy governs all personal information collected by or provided to us, and any person who access, use, process, control or otherwise handle personal information on our behalf will act in accordance with this Privacy Policy. We process personal data that is considered necessary in order for us to conduct our activities and services.

In accordance with Article 6 (1)(b) & (f) of the GDPR, we only process personal data when processing is necessary for the performance of a contract, or when processing is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.

3. Candidates

3.1 Collection of personal data
In order to provide the ideal employment opportunities to you, we must collect certain data about you, so that we can tailor each employment opportunity to each candidate. Below we outline how your personal data are being collected and what type of personal data are being processed in our recruitment processes.

We collect your personal data directly from you when you register your CV on our company’s website (, or when you apply for a vacancy published online on LinkedIn or our website. Based on your CV and other relevant documents e.g., cover letter, recommendation letters, diplomas, certifications that you choose to upload we perform an in-depth screening through interviews, job simulations, tools and references, during which we collect a set of additional data assessing your skills, personality, ethics, and professionalism.

We may also collect your personal data through direct communication such as phone calls, emails, or physical or virtual meetings.

We may also collect your personal data from external sources if relevant and legitimate. This may include personal or professional information disclosed by referees or clients. *In order to reach out to referees we obtain contact details from data subjects [you] as part of the assessment process. Contact details of employers and referees may be obtained through Candidates and Talents or other external sources, and may include name, phone number or email address.

We collect data such as your name, age, contact details, address, education history, employment history, financial information, information on your personal interests, other information that you choose to share with us, other information that your referees choose to tell us about you, and other information that our clients choose to tell us about you.

Please note that the above factors of personal data are not exhaustive, and as such we may collect other data points if deemed relevant.
As part of the recruitment, we require you to partake in assessment and development activities such as psychometric evaluations and skill tests, which are conducted through a trusted third-party service provider. These tests allow us to ensure the right organisational fit in the recruitment process.

Please note that recruitment processes often include the gathering of personal data from prospective candidates, before data subjects [you] submit their CV. Clients will in some instances nominate a candidate, internal or external, and we may in this process collect limited data. If you reach out to us, or if we believe you would be interested in our services, we will collect information about you, to determine how we may assist you.

This limited data will likely include your name, occupation and contact details, so that we can contact you regarding a current or future employment opportunity.
If you have uploaded your CV, exam transcripts or other applications through our website, we may also collect personal data such as employment history, education, qualification, skills, personal interests, or future job preferences.
Similarly, we may also collect other information about you from LinkedIn, other job sites, external recommendations, as well as any other information which you have made publicly available.

3.2 How do we use your personal data?
We use candidate data for our recruitment activities, and for documenting that the recruitment process was fair and legitimate, and without discrimination.

For Talents: We use your personal data to assess your qualifications and personality and match you with a potential employment opportunity. The more we know you, your skillset, and your job preferences, the better we can match your ambitions with job openings.

Prospective Candidates: We use your personal data when assessing the possibility of taking you on as a candidate for an employment opportunity.

Data obtained from data subjects: We use externally obtained data, namely references, to confirm the Candidates qualifications and employment history, as well as evaluating the referee’s professional experience with the Candidate.
We will never use your personal information for purposes which you would not reasonably expect us to use it for.

3.3 Who do we disclose your personal data with?
Personal data may be disclosed to the extent required for recruitment purposes.

For Talents: We will disclose your personal information to clients with whom we have entered a service agreement with. We may also disclose your personal information with relevant employees within the client’s organisation, namely HR employees or relevant stakeholders. Before we disclose your personal data with clients, we will implement measures that, to an extent, ensure that the client will remain compliant when handling your data.

For Prospective Candidates: We will only disclose Prospective Candidates data internally.

3.4 How long do we keep your personal data for?
We believe that is it reasonable to assume, that if you as a Talent or Prospective Candidate, have applied for a job opening or registered your CV on our website, that you understand that we will store your personal data for the purpose of providing recruitment services.

For Talents: Osander keeps a database of Talents who have applied for job openings or registered their CVs on our website. Your personal data will be deleted after a 2-year period. After the 2-year period, we may ask you to confirm that you wish to remain in our candidate database.

For Placed Talent: If you, through Osander, was placed in a job, we will keep your data for 2 years for legal and tax purposes. 

4. Clients
In general, we only collect limited personal data from clients, and only for recruitment purposes.

4.1 What kind of personal data do we collect and how?
We obtain data from our clients, their organisation, and other people from the organisation in order to ensure a mutual understanding of the scope of the executive search. This data may include names, phone numbers or email addresses of relevant personnel in the organisation.

We may also collect data that the client chooses to disclose for the purpose of facilitating our service offerings to the client, or data that is considered relevant or legitimate.

We may request you or individual contacts within your organisation, to complete a customer satisfaction survey, or to provide a written or oral testimonial of our services, to be used for marketing purposes.

4.2 How do we use your personal data?
We use Client data to ensure that both parties are aligned on the scope and expectations of the services. Using client data allows us to identify Candidates or Prospective Candidates who will match the executive’s personality and the organisational structure and culture. The more information we have, the better we can tailor our services to you.

4.3 Who do we disclose your personal data with?
We will disclose Client data with candidates, associated third parties or other service providers, if it is required for the recruitment purposes. Client data will be publicly disclosed if Osander handles public job posts on LinkedIn or other job sites, if so requested by the client.

4.4 How long do we keep your personal data for?
We retain your personal data in order to provide services to you. We also store your personal data to provide you with information about our services if we expect you to be interested in them.

We keep records of our meetings, conversations, candidate presentations and placements to document the fulfillment of our contractual obligations. If you explicitly request that we delete your data, we will do so to the extent, that regulation and law allows us. We may in some instances be required to retain your personal data in connection with law, regulations or tax authorities.

5. Site visitors
We may collect data about how you use our website, which job openings you apply for, and how frequently you visit our website to continually improve your browsing experience. In addition, we use cookies to automatically collect your data, when you agree with our cookie policy.

Unless you specify otherwise, we will share your data with web service providers and third parties. Processing of the personal data obtained from site visitors are processed by a third-party web service provider, and not Osander.

When you visit the site for the first time you will be notified of our cookies policy. If you choose to continue browsing the website, you agree to our use of cookies. Managing, deleting or rejecting cookies can be done by the data subject [you], through your browser’s privacy settings.

6. Your rights
Osander strives to always remain compliant with GDPR rules, and you therefore have different rights in relation to your personal data. Should you wish to act on any of the following rights as a data subject, please contact our Privacy Officer (contact details are at the bottom of the page).

6.1 Right of Access
You have the right to access your personal data as well as modify, update or delete your information at any time. We seek to comply with any such request as fast as possible, but we occasionally will:

– Seek confirmation on your identity as well as your request to ensure that the request will be executed correctly.
– Deny your request. We take your personal data seriously and fully acknowledge that it belongs to you alone. However, we may be lawfully required to retain your personal data in some instances. If we deny your request, we will provide reasoning for doing so.

6.2 Right of Rectification
You have the right to rectify inaccurate or incomplete personal data concerning you.

6.3 Right to Erasure
You have the right to have your personal data deleted (the right to be forgotten). The right to Erasure is applicable when:

– The personal data is no longer deemed relevant for its original purpose.
– You withdraw consent, where there is no legal ground for processing.
– The personal data has been unlawfully processed.
– The personal data has to be erased for compliance with a legal entity.
– The above situations are not exhaustive. See Article 17 of the GDPR for a complete overview.

6.4 Right to Withdraw Consent
You have the right to withdraw your consent at any given time. The right to consent is applicable when the processing of your data is based on consent.

Please note, that by withdrawing consent, we will no longer be able to help you find a job, or provide you with recruitment services. The right to withdraw consent does not apply if the processing is required to perform a contract or to comply with legal obligations. This is in accordance with Article 6 (1)(b) & (f) of the GDPR.

6.5 Right to Data Portability
You have the right to demand all your personal data in a readable document. When Data Portability request are made, we export your personal data to you.

6.6 Right to Object
We process your data when it is necessary to conduct recruitment services. We argue that this is in both our and your legitimate interest, but if you do not agree, you have the right to object.

7. Contact
Privacy Officer Details: Albert Nogawa

Email address:

Last updated: 29/04/2022