Jatpo Career Portal
Privacy Policy
DRAFT — for legal review before publication
Version 0.2 · [Insert effective date] · Prepared for Jatpo
Table of Contents
1. Introduction
This Privacy Policy explains how Jatpo ("Jatpo", "we", "us", or "our") collects, uses, stores, shares, and protects personal data submitted through the Jatpo Career Portal (the "Portal"), including the Talent Pool Registration, the Job Postings Board, and the internal Admin Portal used by Jatpo team members to manage candidate records.
This Policy is written to align with the EU General Data Protection Regulation (GDPR) and India's Digital Personal Data Protection Act, 2023 (DPDP Act). It is intended for candidates located in, or whose data processing otherwise falls under, jurisdictions covered by the GDPR, the DPDP Act, or frameworks that recognise/are deemed adequate under either regime. It does not address other regional data protection laws (e.g. US state laws, China's PIPL), which are treated as out of scope for this version.
Note: This is a working draft, not a substitute for legal advice. It should be reviewed by a qualified data protection lawyer familiar with GDPR and DPDP requirements before publication, and adapted as Jatpo's legal entity structure evolves.
2. Who We Are — Data Controller / Data Fiduciary
For the purposes of the GDPR, Jatpo acts as the "Data Controller" of the personal data processed through the Portal. For the purposes of the DPDP Act, Jatpo acts as the "Data Fiduciary".
Field | Details |
Entity | Jatpo (sole proprietorship / Einzelunternehmen) |
Registered address | [Insert business address] |
Country of establishment | Germany |
Contact email (privacy) | [Insert privacy contact email — e.g. talentpool@jatposolutions.com or a dedicated privacy address] |
EU representative (if applicable) | [Insert, if Jatpo has no EU establishment but targets EU data subjects] |
Grievance Officer (DPDP requirement) | [Insert name, designation, and contact details] |
3. Scope of This Policy
This Policy covers three related surfaces:
Talent Pool Registration — an open, proactive registration where any individual may submit their profile to Jatpo's talent pool without applying to a specific job.
Job Postings Board — a browse-only listing of open roles. The Job Postings Board does not collect personal data directly; there is no "apply" function on this page. Candidates interested in a role are directed to the Talent Pool Registration.
Admin Portal — an internal, access-controlled system used by authorised Jatpo team members to review, search, tag, and manage candidate records (see Section 9).
This Policy applies to all personal data processed across these surfaces, including data collected at registration, data added or changed afterward, data generated internally while managing a candidate's profile (e.g. status changes, notes), and technical/derived data created for internal functions such as search (see Section 4.3).
4. Personal Data We Collect
The Portal distinguishes between candidate-editable data (submitted and updatable by the candidate) and company-only data (recorded internally by Jatpo and not directly editable by the candidate).
4.1 Candidate-editable data
Identity and contact details (e.g. first and last name, age, country and city of residence, email address)
Professional profile information (e.g. highest education completed, field of study, certification/issuing institution, top skills with self-rated expertise, languages spoken with proficiency level, professional networking profile URL)
Preferences (e.g. preferred work location and remote/on-site preference, interested employment types, preferred job titles and industries, availability, compensation expectation)
Consent choices (e.g. mandatory talent-pool consent, optional marketing/newsletter consent — see Section 6)
4.2 Company-only data
System-generated candidate identifier (format JATPO-DE-DDMMYY-NNN)
Recruitment status (one of: New, Reviewed, Shortlisted, Engaged, Active, Inactive, Archived)
Append-only, timestamped status change log recording status transitions over time
Internal notes and tags recorded by Jatpo team members or contributors involved in reviewing candidates (notes may be edited, with edit history preserved)
Metadata such as registration date, source, and record last-modified date
4.3 Technical and derived data
Account security data: login timestamps, password-change events, and session tokens, used to secure candidate accounts (see Section 7)
A backend-only "shadow field" storing a diacritic-normalised copy of certain text fields (last name, city, university name) to power internal search — e.g. matching "Müller" and "Mueller". The candidate's original entry is always stored and displayed unmodified; the normalised copy is never shown to the candidate and is used solely for internal Admin Portal search matching.
Note: The exact field list should be finalised against the current Unified Requirements Document (URD) for the Portal before publication, so this Policy accurately reflects what is actually collected.
5. How and Why We Use Personal Data (Legal Bases)
We process personal data for the purposes and on the legal bases set out below. Under GDPR Article 6, we rely on the bases indicated; under the DPDP Act, processing is generally grounded in the candidate's consent, given at the point of registration, or another applicable ground under the Act (e.g. legitimate uses expressly permitted by law).
Purpose | GDPR legal basis | DPDP basis |
Maintaining the candidate's talent pool profile | Consent (Art. 6(1)(a)) / Contract steps at candidate's request (Art. 6(1)(b)) | Consent |
Evaluating suitability for current or future roles | Legitimate interests (Art. 6(1)(f)) — recruitment | Consent |
Communicating with the candidate about their profile or opportunities | Consent / Legitimate interests | Consent |
Sending optional marketing/newsletter content | Consent (Art. 6(1)(a)) — separate, opt-in | Consent — separate, opt-in |
Securing candidate accounts (login, password reset, session management) | Legitimate interests (Art. 6(1)(f)) — security | Legitimate uses permitted under the Act — security of processing |
Maintaining status history and internal records for accountability | Legitimate interests | Consent / legal obligation where applicable |
Complying with legal obligations | Legal obligation (Art. 6(1)(c)) | Legal obligation |
Note for legal review: recruitment evaluation is mapped to "legitimate interests" under GDPR but to "consent" under DPDP. This reflects the two laws' different structures, but should be confirmed by counsel rather than treated as a like-for-like mapping — the DPDP Act's list of non-consent ("legitimate uses") grounds is narrower than GDPR's legitimate-interests basis, so a purpose lawful under one basis in one law may need a different justification in the other.
Where processing relies on consent, candidates may withdraw that consent at any time, as described in Section 11. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. Consent Management and Records
Where we rely on consent as the legal basis for processing, we record and version that consent at the level of each individual purpose, rather than as a single blanket agreement. This allows a candidate to consent to some purposes (e.g. talent pool storage) without necessarily consenting to others (e.g. marketing emails), and allows us to demonstrate exactly what a candidate agreed to and when, as required by both GDPR and the DPDP Act.
Registration itself uses double opt-in: after submitting the Talent Pool Registration form, a candidate must confirm their email address via a confirmation link before their profile and consent record become active.
For each candidate and each purpose, we maintain a consent record containing the following fields:
Field | Why we record it |
candidate_id | Links the consent record to the candidate's profile (format JATPO-DE-DDMMYY-NNN). |
consent_text_version | A version identifier pointing to the exact wording of the notice shown, rather than the raw text itself — since policy wording changes over time, this lets us determine precisely which version a candidate agreed to. |
purpose(s) | The specific purpose(s) consented to, recorded as separate consents rather than a single blanket checkbox — e.g. "talent pool storage" (mandatory) and "marketing/newsletter emails" (optional). |
consent_given | Boolean flag recording whether consent was given. |
timestamp | The date and time consent was given. |
method | How consent was captured, e.g. "checkbox at registration, confirmed via double opt-in email link" or "re-confirmed via email link". |
withdrawal_timestamp | Nullable field recording the date and time consent was withdrawn, if applicable. |
locale/language | The language/locale version of the notice the candidate was shown, so we can reproduce exactly what they read. |
Each time this Privacy Policy or a specific consent notice is materially updated, it is assigned a new consent_text_version. Candidates may be asked to re-confirm consent against the updated version where required by law. Consent records, including their history, are retained for as long as necessary to demonstrate compliance, and are handled in line with Section 8 (Data Retention).
7. Account Security and Audit Logs
Separately from consent records, we keep security and audit logs to protect candidate accounts and to detect misuse. These logs are treated as a distinct record category from consent records, with their own retention rules (see Section 8), because they serve a different purpose (account security, not evidencing consent).
Login events and password-change events
Session information used to invalidate other active sessions when a password is reset
Notifications sent to the candidate when their password is changed or their account is otherwise modified, including a "secure my account" link if the candidate did not make the change themselves
These logs are used solely for account security, fraud prevention, and abuse mitigation (e.g. rate-limiting repeated login or reset attempts), and are not used for recruitment evaluation or shared with anyone outside Jatpo except where required by law.
8. Data Retention
We keep different categories of data for different lengths of time, matched to why we hold them:
Candidate profile data — retained according to the candidate's status in the recruitment lifecycle. Active statuses (New, Reviewed, Shortlisted, Engaged, Active) are retained for as long as the candidate remains part of the active talent pool. Inactive profiles are retained for a defined period to allow re-engagement, after which the profile is reactivated, archived, or deleted. Archived profiles are retained in line with a defined archival retention period, after which data is deleted or irreversibly anonymised, unless a longer period is required by law.
Consent records (Section 6) — retained for as long as the underlying profile exists, plus an additional period afterward where needed to demonstrate historical compliance.
Security and audit logs (Section 7) — retained for a shorter, fixed period distinct from profile and consent data. [Exact period still being finalised internally — under consideration: 90 days to 1 year.]
[Insert final, specific retention periods for each category above, e.g. "Inactive profiles are reviewed after 12 months" and "Archived records are deleted after 24 months", once finalised internally.] Candidates may also request earlier deletion of their profile at any time, as described in Section 11, subject to any retention we are legally required to maintain (e.g. for audit or legal-claims purposes).
9. How We Share Personal Data
Jatpo operates with a remote-first, global contributor model. Personal data may be accessed by:
Authorised Jatpo team members and contributors (including freelancers, volunteers, and developers) who need access to perform recruitment-related tasks, subject to confidentiality and data-handling obligations.
Service providers who host, store, or process data on Jatpo's behalf (e.g. hosting/infrastructure providers), acting as processors under GDPR / significant data processors or processors under the DPDP Act, bound by data processing agreements.
Authorities or third parties where required by law, or to establish, exercise, or defend legal claims.
We do not sell personal data. We do not knowingly share candidate data with third parties for their own independent marketing purposes.
9.1 Internal access via the Admin Portal
Jatpo team members access candidate data through an internal, access-controlled Admin Portal, with two role levels carrying different permissions:
Admin — full access, including bulk actions, data export (CSV, all visible columns), and user management for the Admin Portal itself.
Talent Coordinator — day-to-day candidate review access (search, filtering, status updates, notes/tags), without export or user-management permissions.
Notes and tags added to a candidate's record may be edited by authorised staff; edit history is preserved rather than overwritten, and consent/audit-log visibility within the Admin Portal is restricted to the Admin role.
[Insert names/categories of specific external sub-processors once finalised, e.g. cloud hosting provider, email service provider.]
10. International Data Transfers
Given Jatpo's global, remote-first contributor model, personal data may be accessed or stored by contributors located in different countries. Jatpo limits registration, storage, and transfer of candidate data to countries that fall into one of two groups: (a) countries covered by the GDPR/EEA or subject to a European Commission adequacy decision, or India under the DPDP Act; or (b) countries with no domestic data protection law of their own. Countries that maintain their own separate data protection regime requiring independent compliance (for example, registration/authorisation or their own cross-border transfer restrictions) are excluded from the Portal's country-of-residence options, even if not otherwise a high-risk jurisdiction.
Jatpo does not transfer candidate personal data to, or process it in, the United States or China, and does not process data in countries that do not fall under the approved list below, unless a candidate is separately informed and appropriate safeguards (such as Standard Contractual Clauses or an approved transfer mechanism) are put in place.
The current approved country list (also used to determine which countries are selectable as "Country of Residence" at registration) is set out in Appendix A.
11. Candidate Rights
Depending on the applicable law, candidates have the following rights over their personal data:
11.1 Rights under GDPR
Right of access to their personal data
Right to rectification of inaccurate or incomplete data
Right to erasure ("right to be forgotten"), subject to legal exceptions
Right to restrict processing in certain circumstances
Right to data portability
Right to object to processing based on legitimate interests
Right to withdraw consent at any time, without affecting prior lawful processing
Right to lodge a complaint with a supervisory authority
11.2 Rights under the DPDP Act (as Data Principal)
Right to access information about how personal data is processed
Right to correction and completion of personal data
Right to erasure of personal data no longer necessary for the stated purpose
Right to grievance redressal via Jatpo's Grievance Officer
Right to nominate another individual to exercise these rights in the event of death or incapacity
Right to withdraw consent at any time
11.3 How to exercise these rights
Most profile data (identity, professional details, preferences, and the optional marketing consent) can be viewed, corrected, or withdrawn directly by the candidate through their account. For anything not available through self-service — including a full copy of held data, erasure of company-only fields, or a formal complaint — candidates can contact us at [insert privacy contact email].
We aim to acknowledge rights requests promptly and to respond within the timeframe required by applicable law (generally within one month under GDPR, extendable in complex cases; within the timeframe prescribed under DPDP Act rules). [Insert final confirmed response-time commitment and any identity-verification step once the request-handling process is finalised internally.]
12. Data Security
We apply reasonable technical and organisational measures appropriate to Jatpo's scale and resources to protect personal data against unauthorised access, alteration, disclosure, or destruction, including role-based access controls in the Admin Portal, authenticated candidate accounts with password-reset and session-invalidation controls (see Section 7), and confidentiality obligations for team members and contributors.
[Insert further detail once specific security measures — encryption at rest/in transit, hosting provider security certifications, rate-limiting thresholds, etc. — are finalised.]
13. Cookies and Other Tracking Technologies
The Portal may use cookies or similar technologies strictly necessary to operate candidate accounts, such as maintaining a logged-in session. [Confirm and expand once the Portal's actual cookie usage is finalised: specify whether any analytics, performance, or preference cookies are used in addition to strictly-necessary session cookies, and whether a cookie-consent banner is required for non-essential cookies under applicable law.]
Where non-essential cookies are used, candidates will be asked for consent in line with Section 6, separately from talent-pool and marketing consent.
14. Children's Data
The Portal is intended for individuals of working age and is not directed at children. We do not knowingly collect personal data from children under the age defined as a "child" under applicable law (16 under GDPR, unless a lower age set by member state law applies; 18 under the DPDP Act). If we become aware that we have collected such data without appropriate consent, we will take steps to delete it.
15. Automated Decision-Making
Recruitment status changes and shortlisting decisions on the Portal are made by Jatpo team members and contributors via the Admin Portal, not by fully automated means producing legal or similarly significant effects on candidates. Search and filtering tools (including diacritic-normalised matching, see Section 4.3) assist staff in finding candidates but do not themselves make or influence recruitment decisions. [Confirm and update this section if any automated scoring or filtering is introduced in future.]
16. Data Breach Notification
In the event of a personal data breach that poses a risk to candidates' rights and freedoms, we will assess the breach and, where required by law, notify the relevant supervisory authority without undue delay (within 72 hours under GDPR, where feasible) and, where the breach is likely to result in high risk to affected individuals, notify those individuals directly. Under the DPDP Act, we will intimate the Data Protection Board of India and affected Data Principals in the manner and timeframe prescribed by applicable rules.
[Insert Jatpo's internal breach-response procedure once finalised — e.g. who is responsible for triage, the internal escalation path, and how affected candidates would be contacted.]
17. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices, the Portal's functionality, or applicable law. We will indicate the date of the latest revision at the top of this Policy and, where changes are material, take reasonable steps to notify candidates. Material changes affecting a specific consent purpose will be reflected in a new consent_text_version as described in Section 6.
18. Contact Us and Grievance Redressal
For questions about this Policy or to exercise your rights, please contact:
Privacy contact: [Insert email]
Grievance Officer (DPDP Act): [Insert name, designation, and contact details]
Postal address: [Insert address]
If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection supervisory authority (under GDPR) or the Data Protection Board of India (under the DPDP Act).
Appendix A: Approved Countries for Data Processing and Transfer
The following countries are approved as "Country of Residence" options at registration and for related data storage/transfer, on the basis set out in Section 10.
A.1 GDPR/EEA member states and countries subject to an EU adequacy decision
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Iceland, Liechtenstein, Norway, Andorra, Argentina, Brazil, Faroe Islands, Israel, Japan, New Zealand, South Korea, Switzerland, United Kingdom, Uruguay.
A.2 India (DPDP Act) and countries with no domestic data protection law
India, Bangladesh, Belize, Burundi, Cambodia, Central African Republic, Cuba, Dominica, Eswatini, Ethiopia, Guyana, Haiti, Jordan, Libya, Maldives, Myanmar, North Korea, Pakistan, Rwanda, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Timor-Leste, Venezuela.
Note: This list is maintained internally as the Portal's registration compliance list and should be kept in sync between the Portal's country dropdown and this appendix whenever it is updated.