Effective Date: March 31, 2020
Information We Collect
We may collect personal data about you in a variety of ways, such as through our Sites and social media channels; at our events; through phone and fax; through job applications; in connection with in-person recruitment; or in connection with our interactions with clients and vendors. We may collect a selection of personal data dependant on the nature of the relationship, including, but not limited to:
contact information (such as name, postal address, email address and telephone number);
username and password when you register on our Sites;
information you provide about friends or other people you would like us to contact (the Data Controller assumes that the other person previously gave an authorisation for such communication); and
other information you may provide to us, such as in surveys or through the "Contact Us" feature on our Sites.
In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data to the extent permitted by law:
employment and education history;
language proficiencies and other work-related skills;
government-issued identification such as drivers licence number;;
date of birth;
bank account information;
citizenship and work authorisation status;
information provided by references; and
information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment.
We may also collect the following types of personal data upon receiving your explicit consent (where required by applicable law):
disabilities and health-related information; and
results of drug tests, criminal and other background checks.
ManpowerGroup may set up a profile for an associate or job candidate on iProfile based on the information provided to us or collected by us. iProfile is a database of candidate information which may be shared with other registered organisations, but only where the individual job candidate or associate has previously registered (or in the future registers) with another compatible organisation. Providing the information to ManpowerGroup is confirmation that you consent to the disclosure, processing and use of the information to set up a profile for you on iProfile using Greythorn Pty Ltd, an iProfile compatible organisation (further information is available on the following URL address: http://www.iprofile.org/.
In addition, we may collect information you provide to us about other individuals, such as information related to emergency contacts.
How We Use the Information We Collect
The Data Controller collects and uses the data gathered for the following purposes:
providing workforce solutions and connecting people to work;
creating and managing online accounts;
managing our business partner, client and vendor relationships (including those providing services to us);
where permitted under law, for communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
responding to individuals' inquiries and claims;
operating, evaluating and improving our business (including developing, enhancing, analysing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities; and
complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.
All processing will be carried out based on adequate legal grounds which may fall into a number of categories, including:
consent or explicit consent from the data subject, where required by applicable law;
to ensure that we comply with a statutory or contractual requirement, or a requirement necessary to enter into a contract (e.g. processing your personal data to ensure that your wages and taxes are paid correctly); or
it is essential and necessary for the legitimate interest of the Data Controller, as described in more detail below (e.g. allowing access to a website in order to provide the services offered).
Providing you with job opportunities and work;
providing HR services to you, including administration of benefit programs, activity capture systems, payroll, performance management and disciplinary investigations or actions;
providing additional services to you, such as training, career counselling and career transition services;
assessing your suitability as a job candidate and your associate qualifications for positions; and
performing data analytics, such as (i) analysing our job candidate and associate 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).
We also may use the information in other ways for which we provide specific notice at or prior to the time of collection.
If you apply for a job and do not provide all of the information required, we may be unable to consider you for employment opportunities or provide other services to you.
Use of Automated Data Collection Methods
When you visit our Sites, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Sites, dates and times of visits to our Sites and other usage statistics.
A "cookie" is a file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser.
A "web beacon" also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server.
Through these automated collection methods, we may obtain "clickstream data," which is a log of the links and other content on which a visitor clicks while browsing a website.
Our Sites use these types of cookies:
Technical cookies are those used exclusively with a view to "carrying out the transmission of a communication on an electronic communications network, or insofar as this is strictly necessary to the provider of an information society service that has been explicitly requested by the contracting party or user to provide the said service."
Profiling cookies are aimed at creating user profiles. They are used to send ads messages in line with the preferences shown by the user during navigation. In light of the highly invasive nature of these cookies, vis-à-vis users' private sphere, local and European legislation requires users to be informed appropriately on their use so as to give their valid consent.
How We Collect Information by Automated Means
As you click through our Sites, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Your browser will allow you to block cookies, however, you may not be able to use all of the features of our Sites without cookies.
Providers of third-party apps, tools, widgets and plug-ins on our Sites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, ManpowerGroup is not responsible for these providers' information practices.
To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
How We Use Information Collected Through Automated Means
We use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as:
customising our users' use of our Sites;
delivering content tailored to our users' interests and the manner in which our users use our Sites; and
managing our Sites and other aspects of our business.
We also use third-party analytics services on our Sites, such as those of Google Analytics and Adobe Omniture. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse your use of our Sites. The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the Sites. To learn more about these analytics services and how to opt out, please visit the following sites and any sites contained in the country-specific addenda:
Google Analytics: tools.google.com/dlpage/gaoptout
Adobe Analytics: adobe.com/privacy/analytics.html#1
Profiling and Interest-Based Advertising
On our Sites, we may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served.
You may see certain ManpowerGroup ads on other websites because we engage third-party advertising networks. Through such advertising networks, we can target our messaging to users through demographic, interest-based, behavioural and contextual means. Through the ad networks, we can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests and previous activity. The information our advertising networks may collect on our behalf includes data about your visits to websites that serve ManpowerGroup advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, please visit aboutads.info/choices/. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our Sites are not designed to respond to "do not track" signals from browsers.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and ManpowerGroup is not responsible for those providers' information practices.
Links to Third-Party Sites, Apps and Services
For your convenience and information, our Sites may provide links to third-party sites, apps and services that may be operated by companies not affiliated with ManpowerGroup. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-ManpowerGroup sites, apps or services.
How We Process and Protect Personal Information
We process the personal data we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal retention policy, in order to ensure that the personal data are not kept longer than necessary.
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. In order to ensure adequate security and confidentiality of the personal data, we may apply the following security measures as appropriate:
Encryption of data in transit;
Strong user authentication controls;
Hardened network infrastructure; and
Network monitoring solutions.
How Long We Store Data We Collect
We store in our systems the personal data we collect in a way that allows the identification of the data subjects for no longer than it is necessary in light of the purposes for which the data was collected, or for which that data is further processed.
We determine this specific period of time by taking into account:
The necessity to retain the personal data collected, in order to offer services established with the user;
The legitimate interest of the Data Controller, as described in the purposes above; and
The existence of specific legal obligations that make the processing and related storage necessary for specific period of times.
Information We Share
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 reorganisation, dissolution or liquidation).
International Data Transfers
Information collected in Australia will likely be processed in any jurisdiction where you are seeking employment, as well as Singapore, the United Kingdom and the United States. By providing your information you consent to this disclosure.
If you require your Personal Information to be retained in Australia, ManpowerGroup can only comply with this request if a separate and specific agreement is executed with ManpowerGroup in advance of your supply of this information.
Your Rights as a Data Subject
When authorised by applicable law, a data subject may exercise certain specific rights, such as:
Right of access: A data subject may access his or her personal data in order to verify that his or her personal data is processed in accordance with law.
Right to rectification: A data subject may request the rectification of any inaccurate or incomplete data held about him or her, in order to protect the accuracy of such information and to adapt it to the data processing.
Right to lodge a complaint with the Office of the Australian Information Commissioner(OAIC): Every data subject has the right to lodge a complaint with the OAIC if they are not happy with the response they receive from Manpower Group when making a request in relation to their personal information.
If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.
How to Contact Us
If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by writing to:
Privacy Officer, ManpowerGroup
Level 9, 201 Kent Street, Sydney 2000
or sending an email to us at firstname.lastname@example.org
We may charge a reasonable fee for providing that information.
Subsidiaries and Affiliates in Australia to Whom This Policy Applies
Greythorn Pty Ltd.
Manpower Services (Australia) Pty. Ltd.
Marks Sattin (Australia) Pty Limited
Marks Sattin Holdings (AsiaPac) Pty Limited
Right Management Consultants (OC) Pty Ltd.
Right Management Consultants Holdings Pty Ltd
Right Management Consultants International Pty Ltd
Right Management Consultants Pty Ltd