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Privacy & GDPR Compliance

A complete walkthrough of what data WP Career Board stores, how to make it GDPR / CCPA / similar-regulation compliant, and the day-to-day operations a board owner needs to handle (consent, exports, deletion requests, retention).

This is not legal advice - but it covers the technical operations that translate “be compliant” into “do this in the dashboard.”

What data Career Board stores about candidates

Section titled “What data Career Board stores about candidates”

A summary so you know what’s actually on the line:

Data Where When deleted
User account wp_users table On admin-processed erasure, or admin removal
Candidate profile (email, phone, location, bio) WordPress user + user meta With the user account
Resumes (Pro, uploaded files) wcb_resume CPT + media On erasure (deleted)
Applications submitted wp_posts (CPT wcb_application) On erasure: the candidate’s applications are deleted
Cover letters and answers Application meta Deleted with the application
Saved jobs (bookmarks) User meta With the user account
Job alerts (Pro) wcb_job_alerts table (Pro) With the user account
AI vectors (Pro, jobs only) wcb_ai_vectors table (Pro) Kept until the job is deleted

Career Board does not anonymise applications - the privacy eraser deletes the candidate’s applications and resumes outright. There is no “Anonymous candidate” preservation and no wcb_anonymize_or_delete filter.

What data Career Board stores about employers

Section titled “What data Career Board stores about employers”
Data Where When deleted
User account wp_users On removal
Company profile (name, logo, about, locations) wcb_company CPT + meta With company removal
Jobs posted wcb_job CPT When the employer deletes them; when a job is permanently deleted, its applications transition to the job_removed status
Credit ledger (Pro) wcb_credit_ledger table (Pro) Never auto-deleted (append-only financial record; admin purges manually if required)
Payment records WooCommerce / PMPro / etc. (Pro checkout) Per that plugin’s deletion policy

What you legally need to do (typical GDPR baseline)

Section titled “What you legally need to do (typical GDPR baseline)”
  1. Disclose what you collect in a privacy policy on the site.
  2. Obtain consent before collecting (typically a checkbox on registration / apply forms).
  3. Provide data exports when a user requests their data (right of access).
  4. Provide data deletion when a user requests it (right to erasure).
  5. Set a retention policy (don’t keep data forever without reason).
  6. Notify on breach within 72 hours of detection.

The technical operations:

Step 1 - Privacy policy text

Section titled “Step 1 - Privacy policy text”

Career Board doesn’t generate your privacy policy text, but here’s a template paragraph to add to yours:

Job Board Data: When you register on this site as a candidate or employer, we collect the information you provide (name, email, resume, profile details, job postings, applications). We store this on our servers running WP Career Board. We use this data to show your profile / jobs / applications to relevant parties on the board. We do not sell this data. You can request a full export or deletion of your data at any time from Candidate Dashboard → Settings (Export my data / Delete my account). Requests are processed by the site administrator through WordPress’s privacy tools.

AI Features: If we have AI features enabled, your data may be sent to a third-party AI provider (OpenAI, Anthropic Claude, or Ollama on our own server) for processing. See the AI provider’s own privacy policy for their handling. You can opt out of AI processing by [linking to the opt-out mechanism if you have one].

Payment Data: If you purchase services (e.g. job posting credits, subscriptions), payment is processed by [WooCommerce / PMPro / etc.] - see their privacy policy for payment data handling.

Update the bracketed bits to your specifics. Always have a lawyer review the final version.

Step 2 - Consent capture

Section titled “Step 2 - Consent capture”

Career Board does not ship a built-in consent checkbox or a “Settings → Privacy → Consent text” screen, and it does not log a _wcb_privacy_consent meta value. If your jurisdiction requires explicit consent at registration or apply time, add it yourself:

  • Use a consent-management / forms plugin, or
  • Add a required checkbox to the registration / apply forms via the form field filters (for example wcb_candidate_form_fields, wcb_application_form_fields_groups) and store the result on the user or application.

Always link your privacy policy from wherever you collect data.

Step 3 - Handling data export requests (Right of Access)

Section titled “Step 3 - Handling data export requests (Right of Access)”

Career Board uses WordPress’s standard privacy request flow for both export and erasure - it does not generate its own instant ZIP download.

Option A - User requests it from the dashboard

  1. Candidate Dashboard → Settings → Export my data → Request data export.
  2. This calls WordPress’s wp_create_user_request() with the export_personal_data type, sends a confirmation email to the candidate, and enters the request into WordPress’s privacy queue.
  3. The candidate clicks the confirmation link; the site administrator then completes the export from WP Admin.

Option B - Admin handles it directly

  1. WP Admin → Tools → Export Personal Data (WordPress’s built-in privacy tool).
  2. Enter the user’s email and create the request.
  3. Career Board registers a privacy exporter (via wp_privacy_personal_data_exporters), so the candidate’s applications and status are included in the WordPress export.
  4. The export is delivered through WordPress’s standard download/email mechanism.

Career Board’s exporter is paginated, so it works on large accounts without a single timeout-prone query.

Step 4 - Handling data deletion requests (Right to Erasure)

Section titled “Step 4 - Handling data deletion requests (Right to Erasure)”

For candidates:

Option A - User requests it from the dashboard

  1. Candidate Dashboard → Settings → Delete my account → Send confirmation email.
  2. This calls WordPress’s wp_create_user_request() with the remove_personal_data type and emails a confirmation link.
  3. The candidate clicks the link; the request enters WordPress’s privacy queue for the site administrator to complete.

Option B - Admin handles it directly

  1. WP Admin → Tools → Erase Personal Data (WordPress built-in).
  2. Enter the user’s email and confirm.
  3. Career Board registers a privacy eraser (via wp_privacy_personal_data_erasers) that runs in pages and deletes the candidate’s applications (and their attached resumes).

What happens on erasure:

  • The candidate’s applications are deleted (wp_delete_post), not anonymised. There is no “Anonymous candidate” placeholder and no wcb_anonymize_or_delete filter - deletion is the only behavior.
  • Removing the user account itself (and reassigning or deleting their authored content) is handled by WordPress’s standard user-deletion flow, which the admin runs alongside the erasure.

For employers:

  1. Use WP Admin → Tools → Erase Personal Data (or delete the user in WP Admin → Users). There is no employer-dashboard “Delete Account” button.
  2. When an employer’s jobs are permanently deleted, every linked application transitions to the job_removed status (the candidate keeps the row in their history).
  3. Credit ledger (Pro): not deleted (append-only financial record). If a jurisdiction requires it, the admin must purge the ledger table manually.

Step 5 - Retention policy

Section titled “Step 5 - Retention policy”

Career Board does not ship a retention settings screen or a retention cron - there is no “Settings → Privacy → Retention” page and no wcb_privacy_retention_cron. The daily crons that do exist handle job expiry, featured-listing expiry, and deadline reminders, not data retention.

If you need scheduled PII purges (e.g. delete applications older than N months), implement them yourself - schedule a WP-Cron event that runs your own cleanup against the wcb_application posts, and document the policy in your privacy notice.

Step 6 - Cookie policy

Section titled “Step 6 - Cookie policy”

Career Board does not set its own tracking cookies. Saved jobs (bookmarks) are stored as _wcb_bookmark user meta for logged-in users - there is no wcb_saved_jobs cookie and no logged-out bookmark feature in Free.

The only cookies in play are WordPress’s standard authentication cookies, the same as any WordPress site. Cover those in your cookie banner as you would for any WordPress install.

Step 7 - AI features and data exposure (Pro)

Section titled “Step 7 - AI features and data exposure (Pro)”

If you have Pro AI enabled, additional disclosure is needed:

  1. Update privacy policy with a section like:

    “We use AI to power [list of features]. When you submit data (resume, profile, application), it may be sent to our AI provider ([OpenAI / Anthropic Claude / Ollama]). Their data handling is governed by [provider URL].”

  2. Per-feature opt-out (optional, custom). Add a checkbox on the apply form via the wcb_application_form_fields_groups filter, then act on it from the wcb_application_submitted action to skip AI ranking when it is unchecked.

  3. Use Ollama for sensitive data. If you can’t share resume / application content with a US LLM (HIPAA, sensitive sectors), run Ollama on your server. See ../ai-features/02-setup-and-providers.md.

Step 8 - Data Processing Agreement (DPA)

Section titled “Step 8 - Data Processing Agreement (DPA)”

For GDPR compliance, your DPA needs to cover:

  • Your role: controller (you decide what’s collected).
  • Sub-processors:
    • WordPress hosting provider (e.g. SiteGround, Kinsta).
    • Payment processor (WooCommerce + Stripe / PayPal).
    • AI provider (if Pro AI is on).
    • Email service (if using SMTP plugin’s provider).
  • Each sub-processor needs its own DPA, which you reference in yours.

This is paperwork, not technical setup. The plugin’s role is to make sure the data flow doesn’t include unexpected processors.

Step 9 - Breach response checklist

Section titled “Step 9 - Breach response checklist”

If you suspect a breach (unauthorised access, data leak):

  1. Identify scope. Which tables / files / accounts were exposed?
  2. Contain. Force-rotate all admin / employer passwords. Disable the affected user accounts if compromised.
  3. Notify affected users within 72 hours (GDPR requirement). Pull the affected user list from WP Admin → Users (filter by the Career Board roles) or with WP-CLI (wp user list).
  4. Notify authorities if the breach meets the threshold for your jurisdiction (each EU state’s DPA, ICO in the UK, etc.).
  5. Patch. Fix the underlying cause. Common causes: outdated plugin, weak admin password, compromised host.
  6. Document. Keep records of what happened, what you did, what was disclosed - for regulator audits.

Common compliance mistakes

Section titled “Common compliance mistakes”
  • No consent checkbox at registration. Career Board does not ship one - add your own (consent plugin or a required field via the form filters) if your jurisdiction requires it.
  • Publishing job activity to the BP stream. Free posts a “[Member] posted a new job” activity entry on publish, and Pro can broadcast more events. Make sure your privacy notice covers any activity that reveals hiring/job-search behaviour.
  • AI providers not disclosed. Adding Pro AI without updating the privacy policy is a quick way to be non-compliant. Always update the policy AND notify existing users of the change.
  • Manual database deletes. Don’t delete rows by hand - use WP’s privacy eraser (Tools → Erase Personal Data) so Career Board’s eraser removes the candidate’s applications and resumes consistently.

Where to go next

Section titled “Where to go next”