The Data Controller is ManpowerGroup Inc with the registered office in Brussels, Belgium. The personal data collected will be controlled and processed by the Data Controller. Additionally, personal data may be processed or controlled by affiliates of the Data Controller. You can access a full list of our subsidiaries and affiliates here.

Where data is shared or made available to other entities, we will always have adequate safeguards in place to protect your information.

This privacy notice applies to:

1. job candidates and recipients of the site career services,
2. users of WorkMyWay and any associated talent community pages or sign-up pages (the "Sites"), and
3. representatives of our business partners, clients and vendors.
   
   This privacy notice does not apply to our employees, who are individuals employed by ManpowerGroup and who work directly for ManpowerGroup, nor any ManpowerGroup associate consultants that we engage with, from time to time, to deliver specific services.

The privacy notice describes the types of personal information we collect, how we use it, how we protect it and for how long we store it on our candidate relationship management database. The notice also outlines data sharing and transfers and the rights that you can exercise regarding our use of your personal data, including how you can contact us to exercise your rights or enquire more about our privacy practices. Our privacy practices are aligned across the countries in which we operate, and you can view specific local terms by visiting local country ManpowerGroup websites.

Depending on our relationship with you, we will collect personal data in variety of ways. If you are a job candidate, we will collect information in connection with in-person or remote recruitment and any subsequent application process. The personal information we collect will always be limited to what is necessary to support the nature of the relationship.

Candidates

If you are a candidate, we may collect your personal information in different ways, depending on how we get to know you:

1. From 3rd party sources.
   

   
   If you are a candidate, we may initially collect your data using a variety of 3rd party resources, for example, job boards, social media, 3rd party agencies or via our clients. We add the personal data collected to our database to link you to an open vacancy or a client talent pool.
   

   At this point we will contact you by email and/or telephone to discuss the opportunity; we may ask you to share your CV or similar information to help us determine whether a vacancy or opportunity is a good match for your skills and experience. If you are interested and a suitable match, we will send you an email to invite you to complete the process by accepting our Terms (specifically, our site Terms of Use, Privacy Notice and Cookie Notice). If you change your mind, or do not wish to accept our Terms, you can select the option to have your personal data removed from our candidate relationship management database. If you choose to ignore the email, we will assume you do not want to hear from us, and we will remove all your data from the system after a period of 30 days.
   

   If you are not suitably aligned with the requirements of the opportunity, or you do not wish to pursue that particular opportunity, we will email you our Terms; if you accept we will keep in touch with you but if you decline or do not respond to the email, we will assume you do not wish to hear from us and remove your personal data from our database within 30 days.
   

   Any candidates sourced by ManpowerGroup, that ManpowerGroup determine are not likely to be aligned with any of the current or future opportunities, will be deleted from the database within 20 days.

2. If you apply for a job or register your interest in a talent pool by using the WorkMyWay Careers page.
   

   
   If you choose to register on WorkMyWay, in order to provide you with the services you have agreed to, we will collect the following information:

   • First name, last name, email address, telephone number
   • The password you create to access your WorkMyWay profile;
   • Your CV, or employment related details from your social media or job board profile; if you choose to parse your social media or job board profile instead of uploading your CV, you can edit and amend the parsed information, giving you full control over what information you use to create your profile;
   • other information you may provide to us directly through the site or in communication with a recruiter.
   • Cookie data collected via cookies essential for the operation of the site
   • Cookie data collected via any non-strictly necessary cookies you explicitly consent to via the cookie banner present on our Sites
     

   If you apply for a position or update your profile to apply for a position, we will process the following types of personal data (as permitted under local law and where it has been determined to be necessary to the opportunity):
   

   • information contained in your CV,
   • information you provide regarding your career interests, and other information about your qualifications for employment;
   • employment and education history;
   • language proficiencies and other work-related skills;
   • information you provide about friends or other people you would like us to contact, for example, for references or in case of emergency. When you provide us with this information, we assume the individual gave you an authorisation for such communication;
   • information you provide in feedback evaluations.
   • Results of assessments - reports and/or scores
   • Record of interactions and any decisions made regarding employment suitability
   • date of birth;
   • gender;
   • references related information; and
     

   Where required by law, and providing explicit consent has been given by you, we may collect:
   

   • disabilities and health-related information, to the extent the information is applicable to your application process;
   • Special categories of data, such as information about ethnic origin, sexual orientation or religion or belief to monitor diversity in recruitment.

   Processing of this sensitive personal information will be done only with your explicit consent and not under the performance of this contract.

3.  If you apply for a job or register your interest in a talent pool by using one of our Sign-Up pages.

If you are a candidate that does not register directly through the WorkMyWay Careers Page in the way described above, we will collect data from you initially via a sign-up page that allows you to either directly apply for a position or join a talent pool. The data collected in this instance will be aligned with the items listed above.

Client, Vendor or Business Partner Representatives

If you are a client, vendor, or any other third-party business partner, we will collect information in connection with our interactions to deliver and make available the agreed services via this site. This may include, but is not limited to your name, your organization's name, your job role, your office/work region/location, your work email address and any contact number you provide to us.

How We Use the Information We Collect

All processing of your personal information will be carried out based on adequate legal grounds. This will include performance of contract, consent and legitimate interest, as described in more detail below.

Performance of Contract

The legal basis for processing candidate personal data, upon acceptance of the Terms of Use and this Privacy Notice, is performance of contract. This enables ManpowerGroup to provide the services agreed i.e. access to current and future job opportunities.

We use the data collected for the following purposes (dependant on our relationship and as permitted under local law):

• providing workforce solutions and connecting people to work;
• assessing candidate’s suitability for available positions and/or client talent pools;
• to send updates regarding available positions, job opportunities and other related communications;
• responding to individuals' queries;
• creating and managing the online account of those users that register via WorkMyWay Careers page.

Consent

If there is a requirement to process any data categorised as sensitive personal data, we will only do this with explicit consent. This data could include, but is not limited to:

• disabilities and health-related information, to the extent the information is applicable to your application process;
• Special categories of data, such as information about ethnic origin, sexual orientation or religion or belief to monitor diversity in recruitment.

This consent can be withdrawn at any time. In this case, there may be circumstances where we will still need to process the data for legal or official reasons but, where legally possible, we will inform the individual if this is the case and ensure data is restricted to what is necessary to meet those specific requirements. Any withdrawal of consent will not affect the lawfulness of the processing before its withdrawal.

We also capture consent for Cookies, where applicable, when you use our sites, consistent with the Data Controller's Cookie Notice (which is incorporated herein by reference);

Legitimate Interest of the Data Controller

The Data Controller will rely on the legitimate interest of its business to process personal data for the following purposes:

• identifying candidates and performing screening activities for an opportunity prior to a Candidate's acceptance of the Terms of Use and Privacy Notice;
• managing client, vendor, and business partner relationships;
• performing data analytics, such as (i) analysing our job candidate base;
• (ii) assessing individual performance and capabilities, including scoring on work-related skills;
• (iii) identifying skill shortages;
• (iv) using information to match individuals and potential opportunities, and (v) analysing pipeline data (trends regarding hiring practices);
• operating, evaluating, and improving our business (including developing, enhancing, analysing, and improving our services and performing accounting, auditing and other internal functions);
• enhancing, modify, personalising, or otherwise improving our services for the benefit of our clients, candidates, and associates;
• protecting against, identifying, and seeking to prevent fraud and other unlawful activity, claims and other liabilities;
• complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations, and our policies;
• if you are a business partner or client representative, we may communicate with you around other available services, programs, special events, offers, surveys, evaluations, and market research;
• to identify and prevent fraud;
• to enhance security of our network and information systems;
• to better understand how people interact with our websites;
• to determine the effectiveness of marketing and/or advertising campaign.

Whenever we process data for these purposes, we will ensure that we keep your rights in high regard and take account of these rights. You have the right to object to such processing; please see the section Your Rights as a Data Subject for information on how to do this. Please be aware that if you exercise your right to object, this may affect our ability to continue to provide you with services for your benefit.

How we Protect Personal Information

We maintain technical and organisational measures designed to protect the personal data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Such measures ensure an appropriate level of security taking account, on one hand, the technical state of the art and, on the other hand, the sensitive nature of Personal Data and the evaluation of potential risks;

To ensure the appropriate security and confidentiality of personal data, we apply to the following non-exhaustive list of measures:

We use the data collected for the following purposes (dependant on our relationship and as permitted under local law):

• Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths;
• Strong user authentication and access controls;
• Network monitoring solutions with events logging;
• Hardened network infrastructure;
• Measures for ensuring physical security of locations at which personal data are processed;
• Business continuity and disaster recovery plans with periodic testing;
• Periodic vulnerability and penetration testing;
• Certification/assurance of processes and products;
• Continuous employee privacy and security training and awareness program;
• Measures for ensuring data minimization, purpose limitation, retention, data quality and accountability.

How Long We Store the Information We Collect

We will keep your personal data for the period necessary to achieve the purposes described in this Privacy Notice, taking into account the nature of our relationship with you, applicable statute of limitation periods and records retention requirements under applicable law. Subject to applicable law, we will retain your personal data as required to meet our business and compliance obligations, for example, to comply with our tax and accounting obligations.

We store the information we collect in our candidate relationship management database in a way that identifies data subjects for no longer than is necessary considering the purposes for the processing. We determine this specific period of time by considering:

• the necessity to store the information collected to offer services to the user;
• the legitimate interests of the Data Controller;
• the existence of specific legal obligations that make the processing and related storage necessary for specific period of times.

Candidates

If you do not agree to the Terms we share with you via email, or you do not respond to the email requesting your acceptance of our Terms, including two subsequent reminders, your personal data will be deleted from our database within 30 days.

If you accept our Terms, you will be contacted by email one year after your acceptance to determine whether you wish to remain registered for opportunities. You will receive two reminders and if you do not reply, your data will be erased from our database, in full, within 30 days. If you advise us you wish to remain registered, this re-validation of your acceptance of our terms will take place on an annual basis.

Once you have agreed to our terms, we will send you emails about employment opportunities, or reminders to e.g. update your preferences or update your CV. At any point, you can opt out of these emails by clicking unsubscribe at the bottom of the email. However, we may still contact you on an individual basis; if you require full erasure of your profile you can contact [email protected].

Candidates who have created an account via WorkMyWay career page can log into their profile and select the delete profile button at any time to have their account erased in full.

Candidates who have taken up employment or assignment with an employer are advised to contact the employer directly if they also wish to have their data removed from the employer's systems/databases.

Information We Share

We share personal data with vendors, for example, IT providers that perform services on our behalf, based on our instructions, to make the Sites and associates services available to you. We do not authorise these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may share your personal data (i) with our subsidiaries and affiliates; (ii) with clients who may have job opportunities available for job candidates and (iii) with others with whom we work, such as job placement consultants, suppliers and subcontractors, for the purpose of finding you a job, creating talent pools or otherwise filling vacancies.

In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

We do not disclose personal data that we collect about you, except as described in this privacy notice or in separate notices provided in connection with other activities.

Data Transfers

When you register on, or otherwise use WorkMyWay, including any Sign-Up page, your data is hosted in the European Union and technical support is provided in both the European Union and in Argentina, which is a country that has been granted a GDPR adequacy agreement by the European Commission.

If there is ever an occasion where will transfer your data to a country not recognised as having GDPR adequacy by the European Commission, we will ensure the transfer takes place only if one of the following is in place;

1. a legally binding and enforceable instrument between public authorities or bodies;
2. binding corporate rules;
3. standard contractual clauses adopted by the European Commission or the Switzerland or UK supervisory authorities, to the extent the processing involves UK or Swiss residents.

Your Rights as a Data Subject

When permitted by applicable law, you can exercise the following rights:

1. Right of access: You have the right to obtain from the controller confirmation as to whether personal data concerning you is being processed, and, where that is the case, access to the personal data.
2. Right to rectification: You have the right to obtain from the controller the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed to protect the accuracy of the information.
3. Right to erasure: Also known as 'the right to be forgotten', you have the right to request that the Data Controller erases information about you and no longer process that data. Please note this is not an absolute right and there may be a valid lawful basis to retain some, or all, of the data collected; this will be made clear to you if this is the case.
4. Right to restriction of processing: You have the right to request the Data Controller restricts the processing of your data.
5. Right to data portability: You have the right to receive the personal data concerning you, that you have provided to the Data Controller, in a structured, commonly used, and machine-readable format. You have the right to request the data is transmitted directly from the Data Controller to another controller.
6. Right to object: You have the right to object, at any time, to processing of personal data concerning you that is being processed under the controller's legitimate business interest, including for direct marketing purposes. You may update your consent to marketing by clicking the 'unsubscribe' facility available at the bottom of any email we send you, or by replying directly to the sender if the email has come from a ManpowerGroup employee.
7. Right not to be subject of automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal or similarly significant effect on or against you. We do not use solely automated decision making on WorkMyWay.
8. Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular, in the country of your habitual residence, place of work or place of the alleged infringement, if you consider the processing of your personal data infringes privacy law.

To withdraw your consent and/or to exercise your right of access, your right to be forgotten, your right to restriction, your right to data portability and your right to object, you can email [email protected].

Updates to Our Privacy Notice

This privacy notice (including any other terms or notices referenced within) may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by indicating at the top of each notice when it was most recently updated.

How to Contact Us

If you have any questions or comments about this privacy notice you can email:
[email protected].