1. Introduction and Scope of Application
WERKLIST DOO (hereinafter: the “Company”, “Agency”, or “WERKLIST”) provides employment mediation services on a global scale. The Company connects qualified candidates with employers worldwide, including markets in the European Union, Southeast Europe, Asia, the Middle East, Latin America, and other regions where the Company operates.

This Employment Policy (hereinafter: the “Policy”) defines the comprehensive framework for handling candidates, processing their personal data, outlining the rights and obligations of all involved parties, and establishing the standards the Company applies throughout the hiring process. The Policy applies to all candidates using the Company’s services, regardless of their country of origin or the country where employment is sought.

By accessing the Company’s services — whether via the website, email, partners, or any other channel — the candidate confirms that they have read, understood, and fully accepted the provisions of this Policy.

Data Controller:
WERKLIST DOO
Svetozara Radojčića 80V, 11050, Belgrade (Zvezdara), Republic of Serbia
Email: fran@werklist.com
Tax ID (PIB): 115344942

2. Definitions
For the purposes of this Policy, the following definitions apply:

“Candidate” — a natural person submitting a job application through the Company or otherwise utilizing its employment mediation services.

“Employer” — a legal or natural person seeking workers for open positions through the Company.

“Mediation” — the service of connecting candidates with employers to establish an employment relationship.

“Temporary Agency Work / Employee Leasing” — a temporary employment service where the Company acts as the formal employer of the assigned worker, while the worker performs duties under the supervision and for the benefit of the user (the company to which they are assigned).

“Application” — the submission of a resume (CV), cover letter, and supporting documentation for employment purposes.

“Personal Data” — any information relating to an identified or identifiable natural person.

“Processing” — any operation or set of operations performed on personal data (collection, recording, storage, use, sharing, deletion, etc.).

“Applicable Regulations” — relevant legislation of the Republic of Serbia, the General Data Protection Regulation (GDPR) of the European Union, the Law on Personal Data Protection of the Republic of Serbia (ZZPL), and all other applicable national and international regulations regarding data protection, labor, and employment.

3. Company Services
WERKLIST provides candidates with the following services within its employment mediation framework:

Employment mediation with domestic and international employers

Professional assistance in preparing resumes (CVs), cover letters, and comprehensive applications

Providing information on working conditions, salary ranges, benefits, and career opportunities

Coordinating job interviews with employers (including both online and in-person interviews)

Assistance in obtaining work permits, residence permits, and visas in accordance with the destination country’s regulations

Organization of travel to the destination country

Assistance in finding suitable accommodation

Support during the integration process (language courses, cultural adaptation, administrative aid)

Mediation in post-hiring communication with the employer

Continuous support for the candidate throughout the duration of the employment relationship

Principle of Free Services: All mediation services provided to candidates are completely free of charge. Under no circumstances and at no point will the candidate be required to pay a fee for employment mediation services. Any request for payment from third parties presenting themselves as representatives of the Company should be immediately reported to branimir@werklist.com.

4. Categories of Collected Personal Data
During the hiring process, the Company collects and processes the following categories of a candidate’s personal data:

4.1. Identification Data
First and last name

Date and place of birth

Gender

Citizenship

Passport or national ID card number

Photograph (from the resume, passport, or submitted separately)

4.2. Contact Data
Email address

Phone number (including communication platforms such as WhatsApp, Viber, etc.)

Postal address in the country of origin

Postal address in the destination country (when applicable)

4.3. Professional Data
Resume (CV) and cover letter

Detailed employment history and previous work experience

Professional qualifications, certificates, diplomas, and licenses

Language competencies and proficiency in the destination country’s language

Specific technical skills and competencies relevant to the requested job position

Recommendations and references from previous employers (when available)

4.4. Employment Documentation
Copy of a valid passport or national ID card

Work permit or documents necessary to obtain a work permit

Medical documentation (strictly when legally mandated for a specific position or by the destination country)

Criminal record certificate (when required for the position or mandated by the destination country’s laws)

4.5. Employment Preferences
Desired positions, industries, and sectors

Salary and benefit expectations

Availability to start work

Preferences regarding work location

Preferences regarding accommodation

Willingness to relocate and geographic flexibility

5. Purposes of Processing Personal Data
Candidate personal data is processed strictly for the following legitimate and predefined purposes:

Application Evaluation — assessing the candidate’s qualifications, experience, and suitability for open positions.

Connecting with Employers — identifying and presenting appropriate employment opportunities.

Administrative Processing — preparing and submitting applications for work permits, residence permits, and visas.

Logistical Support — organizing travel and accommodation in the destination country.

Hiring Coordination — managing the entire hiring process in collaboration with the employer.

Communication — keeping candidates informed about their application status, new opportunities, and relevant updates.

Post-Hiring Support — assisting with integration, accommodation, language adaptation, and resolving any potential issues.

Legal Obligations — fulfilling duties toward competent government authorities in accordance with applicable regulations.

Record Keeping — maintaining legally mandated records related to employment mediation.

Service Improvement — analyzing processes for the continuous enhancement of service quality (strictly using anonymized or aggregated data).

6. Legal Basis for Data Processing
The processing of candidate personal data is based on the following legal grounds:

6.1. Performance of a Contract (Art. 6(1)(b) GDPR / Art. 12(1)(2) ZZPL RS)
Processing is necessary to provide the employment mediation services requested by the candidate, including application evaluation, communicating with employers, and coordinating the overall hiring process.

6.2. Legal Obligation (Art. 6(1)(c) GDPR / Art. 12(1)(3) ZZPL RS)
Processing is required to fulfill the Company’s legal obligations under applicable regulations, including but not limited to labor laws, immigration laws, employment mediation laws, and tax regulations in relevant jurisdictions.

6.3. Candidate Consent (Art. 6(1)(a) GDPR / Art. 12(1)(1) ZZPL RS)
For specific processing activities, such as sharing a candidate’s profile with targeted employers or sending notifications about new job opportunities, the Company requests the explicit consent of the candidate. The candidate reserves the right to withdraw this consent at any time, which does not affect the lawfulness of processing conducted prior to the withdrawal.

6.4. Legitimate Interest (Art. 6(1)(f) GDPR / Art. 12(1)(6) ZZPL RS)
To a limited extent, processing is carried out based on the Company’s legitimate interest in improving services and hiring processes, provided that the Company continually assesses the balance between its legitimate interests and the fundamental rights and freedoms of the candidates.

7. Sharing Data with Employers
Candidate personal data is shared with potential employers exclusively with the prior explicit consent of the candidate. Before any data is shared, the Company follows this procedure:

7.1. Pre-Sharing Procedure
The candidate is fully informed about the employer’s identity, the job description, working conditions, and location.

The candidate’s explicit consent is requested to forward their data to the specific employer.

The candidate is clearly informed regarding which categories of data will be forwarded.

The Company verifies that the employer has implemented appropriate personal data protection measures.

7.2. Scope of Shared Data
Employers are standardly provided with:

Resume (CV) containing the candidate’s professional details.

Contact details (exclusively with explicit consent).

Relevant qualifications, certificates, and diplomas.

Information regarding language competencies.

Other data relevant to the specific position (as agreed upon with the candidate).

7.3. Employer Obligations
Employers receiving candidate data are contractually obligated to:

Use the received data strictly for evaluating the candidate’s application for the specific position.

Not forward candidate data to third parties without prior consent from the Company and the candidate.

Implement appropriate technical and organizational measures to protect the received data.

Delete the candidate’s data after the selection process concludes unless the candidate is hired.

8. International Data Transfer
Given the global nature of the Company’s operations, candidate personal data may be transferred across different jurisdictions. WERKLIST ensures a high level of data protection during every transfer, regardless of the destination country.

8.1. Transfers within the EU/EEA
Transfers of personal data within the European Union and the European Economic Area are conducted in compliance with the GDPR without the need for additional safeguards.

8.2. Transfers within the Republic of Serbia
Transfers are executed in compliance with the Law on Personal Data Protection of the Republic of Serbia (ZZPL).

8.3. Transfers to Third Countries
For transfers to countries outside the EU/EEA and Serbia, the Company applies the following safeguarding mechanisms:

Standard Contractual Clauses (SCCs) approved by the European Commission.

Data Protection Impact Assessments (DPIA) when necessary or legally mandated.

Technical protective measures, including encryption and secure communication channels.

Adequacy assessments of data protection in the destination country.

Additional contractual guarantees with data recipients.

8.4. Regional Standards
The Company complies with local data protection regulations in all regions of operation, including but not limited to:

EU/EEA: GDPR (General Data Protection Regulation).

Serbia: Law on Personal Data Protection.

Southeast Asia (Philippines): Data Privacy Act of 2012 (Republic Act No. 10173).

South Asia (India): Digital Personal Data Protection Act, 2023.

Nepal: Implementation of EU protection standards as a minimum baseline.

Latin America: Compliance with local regulations (Peru — Ley de Protección de Datos Personales; Argentina — Ley de Protección de Datos Personales; Colombia — Ley 1581 de 2012) while applying EU standards as a minimum.

Middle East and North Africa: Compliance with local data protection regulatory frameworks.

Other Jurisdictions: Application of GDPR-equivalent standards as a minimum protective framework.

9. Candidate Obligations
By utilizing the Company’s services, the candidate assumes the following obligations:

9.1. Accuracy and Authenticity of Data
To provide accurate, complete, up-to-date, and truthful personal data.

To submit exclusively authentic and genuine documents (resume, diplomas, certificates, references).

To promptly notify the Company of any changes to personal data, qualifications, or circumstances relevant to employment.

To refrain from falsifying, altering, or manipulating documentation in any manner.

9.2. Active Cooperation in the Process
To actively and conscientiously participate in all phases of the hiring process.

To respond to inquiries from the Company and the employer in a timely manner.

To attend all scheduled job interviews or cancel promptly while providing a valid reason.

To inform the Company without delay if they are no longer interested in the position or have accepted an offer outside the mediation process.

9.3. Compliance with Applicable Regulations
To respect the laws and regulations of both the destination country and the country of origin.

To obtain all necessary work and residence permits in a timely manner.

To strictly adhere to the conditions outlined in the issued work and residence permits.

To report any change in status to the competent authorities within legally mandated timeframes.

10. Application and Hiring Process
The hiring process facilitated through the Company is structured in the following phases:

Application — The candidate submits a resume and supporting documentation via the Company’s website, email, partner network, or other available channels.

Verification and Evaluation — The Company’s expert team assesses the candidate’s qualifications, experience, and suitability for open positions.

Presentation to Employer — Subject to the candidate’s prior explicit consent, their profile is presented to matched employers.

Job Interview — The Company coordinates and organizes the interview between the candidate and the employer (online or in-person).

Employment Offer — If the candidate is selected, the employer issues a formal offer defining the working conditions.

Documentation Preparation — The Company assists in preparing and submitting documentation for work permits, residence permits, and visas.

Travel Organization — Coordinating the logistics of traveling to the destination country (when applicable).

Start of Work — The candidate begins working for the employer with the ongoing support of the Company.

Note: The Company reserves the discretionary right to reject a candidate’s application at any stage of the process, without any obligation to state the reasons for rejection. This right does not impact the candidate’s rights regarding personal data protection.

11. Candidate Guarantees and Consequences of False Information

11.1. Guarantees
By submitting an application, the candidate explicitly guarantees:

That all provided data is accurate, complete, and truthful.

That all copies of documents are authentic and match the originals.

That they possess all qualifications, certificates, and licenses listed in their resume.

That there are no legal or administrative obstacles preventing their employment in the destination country.

That they are authorized to share all provided data.

11.2. Consequences of False Information
In the event that false, incomplete, or misleading data is discovered:

The Company reserves the right to immediately terminate the hiring process without prior notice.

The candidate may face material and legal liability for any damages resulting from the false information.

The employer may terminate the employment contract in accordance with applicable regulations.

The candidate may lose the right to a work and residence permit in the destination country.

The Company may permanently remove the candidate from its database.

12. Employment Conditions

12.1. General Principles
The Company acts as a mediator and does not guarantee employment. The final hiring decision rests solely with the employer.

Working conditions, salaries, benefits, and other rights are determined by the employment contract between the candidate and the employer.

The Company is not a party to the employment contract between the candidate and the employer (except in the case of Temporary Agency Work).

The Company is not liable for decisions made by the employer during or after the hiring process.

The candidate retains the right to reject an employment offer at any time without providing a reason.

12.2. Special Provisions for Temporary Agency Work (Employee Leasing)
In cases involving assigned workers:

WERKLIST is the formal employer of the assigned worker.

The worker performs their duties under the supervision and for the benefit of the user (the assigned company).

Applicable legal provisions regarding temporary agency work in the relevant jurisdiction are observed.

The assigned worker is entitled to equal working conditions as comparable workers employed directly by the user.

13. Accommodation and Travel

13.1. Accommodation

When the Company assists in organizing accommodation in the destination country:

The Company actively helps in identifying and locating suitable housing.

Specific conditions of accommodation (price, duration, standards) are established in a separate contract or agreement.

The candidate is responsible for observing the rules of the accommodation facility and house rules.

The Company assumes no liability for the condition, quality, or changes in terms of properties owned or managed by third parties.

13.2. Travel
When the Company assists in organizing travel:

The Company coordinates travel logistics to the destination country.

The allocation of travel costs (employer/candidate) is determined in advance by written agreement.

The candidate holds sole responsibility for possessing valid travel documents (passport, visas, etc.).

The Company is not liable for delays, cancellations, or travel changes caused by third parties or force majeure.

14. Data Retention Periods
Candidate personal data is retained in accordance with the following periods, applying the principle of data minimization:

14.1. Active Candidates
Data is retained for the duration of the hiring process and up to 3 (three) years following the last active communication with the candidate. The purpose of this extended retention is to allow the candidate to be contacted for future employment opportunities.

14.2. Employed Candidates
Data pertinent to the employment relationship is retained per the legal obligations of the applicable jurisdictions (labor laws, tax regulations, social security codes) for a minimum of 6 (six) years following the termination of employment, or longer if required by the specific jurisdiction’s laws.

14.3. Unsuccessful Candidates
Data is retained for up to 6 (six) months following notification of the application outcome, unless the candidate requests earlier deletion or provides consent for extended retention regarding future opportunities.

14.4. Documentation for Work and Residence Permits
Retained in compliance with the immigration, labor, and residency regulations of the applicable jurisdiction.

14.5. Procedure upon Expiry
Upon the expiration of the applicable retention period, personal data is permanently and irreversibly deleted, or thoroughly anonymized in a manner that makes identifying the candidate impossible.

15. Candidate Rights
In accordance with the GDPR, the Law on Personal Data Protection of the Republic of Serbia, and other applicable regulations, candidates are entitled to the following rights:

15.1. Right of Access (Art. 15 GDPR / Art. 26 ZZPL RS)
The candidate has the right to request and obtain confirmation regarding whether their personal data is being processed, and if so, gain access to that data, including details on the processing purpose, data categories, recipients, and the intended retention period.

15.2. Right to Rectification (Art. 16 GDPR / Art. 29 ZZPL RS)
The candidate has the right to request the correction of inaccurate personal data without undue delay, as well as the completion of incomplete data.

15.3. Right to Erasure (Art. 17 GDPR / Art. 30 ZZPL RS)
The candidate has the right to request the deletion of their personal data (“right to be forgotten”) when the data is no longer necessary for the collected purpose, when consent is withdrawn, or in other legally mandated scenarios.

15.4. Right to Restriction of Processing (Art. 18 GDPR / Art. 31 ZZPL RS)
The candidate has the right to request limited processing of their data in legally defined situations, such as when contesting data accuracy or believing the processing is unlawful.

15.5. Right to Data Portability (Art. 20 GDPR / Art. 33 ZZPL RS)
The candidate has the right to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller without hindrance.

15.6. Right to Object (Art. 21 GDPR / Art. 37 ZZPL RS)
The candidate has the right to object to the processing of their personal data, particularly in instances where the processing is based on the Company’s legitimate interest.

15.7. Right to Withdraw Consent
The candidate can withdraw their provided consent at any time, simply and free of charge. The withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

15.8. Exercising Rights
To exercise any of the aforementioned rights, the candidate may contact: branimir@werklist.com

The Company commits to addressing the candidate’s request without undue delay, and no later than 30 (thirty) days from receiving the request. In cases of complexity or a high volume of requests, this period may be extended by an additional 60 days, about which the candidate will be duly informed.

16. Security Measures
The Company applies comprehensive technical and organizational measures to safeguard candidates’ personal data:

16.1. Technical Measures
Data encryption in transit (SSL/TLS protocols) and at rest (AES-256 or equivalent).

Access control systems featuring multi-factor authentication and role-based authorization.

Routine security audits, penetration testing, and prompt system updates.

Intrusion detection and prevention systems (IDS/IPS) for unauthorized access.

Regular data backups paired with recovery testing.

Secure communication channels for transferring sensitive data.

16.2. Organizational Measures
Restricted access to personal data exclusively for authorized personnel on a strict “need-to-know” basis.

Data Processing Agreements (DPAs) with IT service providers and all sub-processors.

Regular, documented employee training regarding data protection and information security.

A formalized Incident Response Plan.

Enforcement of a clean desk and clean screen policy.

Routine internal audits of data processing operations.

17. Confidentiality

17.1. Candidate Obligations
The candidate is obligated to:

Maintain the confidentiality of all information concerning the Company’s business processes, working methods, and internal procedures.

Not share employer details, working conditions, or offers encountered during the hiring process with third parties.

Not contact employers directly without prior written consent from the Company throughout the mediation process.

Not utilize information obtained from the Company for purposes unrelated to the hiring process.

17.2. Company Obligations
The Company is obligated to:

Maintain the confidentiality of all candidate personal data in compliance with this Policy and applicable regulations.

Share candidate data with third parties exclusively with the candidate’s prior explicit consent or as mandated by law.

Apply all technical and organizational protective measures outlined in Section 16 of this Policy.

Ensure that all Company employees and associates with access to candidate data are bound by appropriate non-disclosure agreements (NDAs).

18. Equal Opportunities and Non-Discrimination
WERKLIST is entirely dedicated to the principles of equal opportunity and non-discrimination. The Company does not discriminate against candidates or differentiate them in any manner based on:

Race, skin color, or ethnic origin

Gender, gender identity, or sexual orientation

Religion, beliefs, or political affiliation

National or social origin

Age

Disability or health conditions

Marital or family status

Union membership

Any other characteristic protected by applicable regulations

All candidates are evaluated purely based on their qualifications, competencies, experience, and suitability for the specific position. Any violation of this principle by a Company employee constitutes a severe breach of labor obligations.

19. Limitation of Liability
The Company is not liable for:

The employer’s decisions regarding hiring, application rejection, or employment contract termination.

Working conditions at the employer that deviate from previously agreed or presented terms.

Delays in the process of obtaining work permits, residence permits, or visas caused by the actions of competent government authorities.

Changes in legislation or regulatory frameworks that affect the feasibility, conditions, or duration of employment.

Damages occurring as a direct or indirect consequence of false, inaccurate, or incomplete information provided by the candidate.

Circumstances of force majeure, including but not limited to pandemics, epidemics, natural disasters, wars, embargoes, sanctions, strikes, or actions by competent authorities.

Notwithstanding these limitations, the Company will, in good faith and with due diligence, endeavor to assist the candidate in resolving any issues or difficulties arising during or after the hiring process.

20. Termination of Services

20.1. Candidate’s Right to Terminate
The candidate may, at any time and without providing a reason:

Withdraw their job application.

Request the deletion of their personal data from the Company’s database (subject to the limitations of legal retention obligations).

Cease using the Company’s services.

20.2. Company’s Right to Terminate
The Company may terminate its services to a candidate in the following instances:

Violation of any provision of this Policy.

Submission of false, forged, or misleading data or documentation.

Delayed or insufficient cooperation during the hiring process.

Behavior that causes or could cause damage to the reputation, business interests, or business relations of the Company.

Behavior that contradicts the principles of professional and ethical conduct.

21. Complaint to the Supervisory Authority
If a candidate believes that the processing of their personal data violates applicable data protection regulations, they have the right to lodge a complaint with the competent supervisory authority.

In all cases, the Company will cooperate with the competent supervisory authority and respect its decisions and recommendations.

22. Whistleblower Protection and Reporting Irregularities
WERKLIST encourages all candidates, employees, and associates to report any irregularities, Policy violations, or suspicious activities. The Company guarantees:

Maximum possible confidentiality regarding the whistleblower’s identity.

Protection of the whistleblower from any form of retaliation or adverse treatment.

Prompt and thorough investigation of all reports.

Implementation of appropriate corrective measures if irregularities are confirmed.

Reports can be submitted to: branimir@werklist.com with the subject line “Confidential — Reporting Irregularities”.

23. Applicable Law and Dispute Resolution
This Policy, alongside all relations arising from the use of the Company’s services, is governed by the laws of the Republic of Serbia, regardless of conflict-of-law provisions, unless applicable international regulations or bilateral agreements mandate the application of another law.

All disputes arising from the use of the Company’s services or in connection with this Policy shall be attempted to be resolved amicably and in good faith. Both parties commit to attempting mediation before initiating court proceedings. If an amicable resolution is impossible, the competent court in Belgrade, Republic of Serbia, shall hold material and territorial jurisdiction.

For candidates who qualify as consumers under applicable regulations, this provision does not waive their right to initiate proceedings before the competent court in their place of residence.

24. Policy Amendments
The Company reserves the right to amend and update this Policy at any time to reflect changes in legislation, the business environment, or internal procedures. Amendments become effective upon the publication of the updated version on the Company’s website or upon notifying candidates via email.

For candidates actively engaged in a hiring process with the Company, significant changes to this Policy will be communicated directly via email or another standard communication channel.

Continued use of the Company’s services following the publication of amendments constitutes acceptance of the updated Policy. A candidate who disagrees with the amendments has the right to stop using the Company’s services in accordance with Section 20 of this Policy.

25. Final Provisions
This Policy is drafted in the Serbian language. In the event of translations into other languages, the Serbian version prevails in cases of discrepancy.

If any provision of this Policy is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect.

Section headings are for convenience only and do not affect the interpretation of the provisions of this Policy.

This Policy forms an integral part of the contractual relationship between the Company and the candidate.

26. Contact
For all inquiries, requests, suggestions, or complaints related to this Policy, personal data protection, or employment mediation services, candidates may contact:

WERKLIST DOO
Svetozara Radojčića 80V
11050, Belgrade (Zvezdara)
Republic of Serbia

Email: branimir@werklist.com