ManpowerGroup’s overriding goal is to ensure the confidentiality, security of the personal data of our Customers, Employees, Job Candidates and Website Users as well as transparency and lawfulness in connection with the processing of such data.
The Privacy Policy describes how personal data is protected and processed in accordance with the standards set forth in applicable laws.
PERSONAL DATA CONTROLLER – STATEMENT OF JOINT CONTROLLERSHIP
Pursuant to Article 13(1) and (2) and Article 14(1) and (2) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ EU L 119, 4.5.2016 (hereinafter referred to as “GDPR”), we would like to inform you that the Joint Controllers of your personal data are the companies of ManpowerGroup (hereinafter referred to as “WADO”):
ManpowerGroup Sp. z o.o. – KRS No. 0000062137, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Transactions Sp. z o.o. – KRS No. 0000339387, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Services Sp. z o.o. – KRS No. 0000228311, registered seat at: 00-105 Warsaw, ul. Prosta 68
MP Actions Sp. z o.o. – KRS No. 0000234796, registered seat at: 00-838 Warsaw, ul. Prosta 68
ManpowerGroup Solutions Sp. z o.o. – KRS No. 0000373518, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Management Sp. z o.o. – KRS No. 0000482136, registered seat at: 90-057 Łódź, ul. Sienkiewicza 85/87
WAYS OF OBTAINING DATA
Directly from Data Subjects as part of ongoing recruitment processes, most often through the Candidate’s expression of a desire to participate in the recruitment process via recruitment forms, candidate accounts, job fair surveys, and by telephone;
Directly from Data Subjects – obtained when Data Subjects use the website;
Directly from Data Subjects at the time of hiring an employee (employment forms, employment contracts, civil law contracts, B2B, medical referrals);
Directly from Data Subjects at the time of joining Benefit programs and internal training;
Indirectly, as part of the sharing of data by other controllers under the law, or as a processor entrusted with the processing of data for the purposes specified by another controller;
Indirectly, through mutual data sharing between business partners, customers and service providers, including contact data of representatives and employees of contracting parties.
Indirectly, as part of the sharing of personal data by third parties and business partners.
AREAS OF JOINT CONTROLLERSHIP
Within the operations of the ManpowerGroup and all of its subsidiaries, we distinguish the following areas of joint controllership:
– RECRUITMENT – an area of internal and external recruitment conducted jointly on behalf of all companies using a common database of job candidates,
– HR AND PAYROLL SERVICE – of internal, external and temporary employees, which is carried out by the HR and Payroll Department shared by all companies,
– PAYROLL – payroll services for external and temporary employees, which is carried out by the Payroll Department shared by all companies,
– ACCOUNTING – conducted for all companies by a common Accounting Department,
– MARKETING AND PUBLIC RELATIONS – carried out by persons employed by WADO jointly for all companies,
– LEGAL SERVICE AND ADVICE – the area of cooperation with customers, keeping a record of commercial contracts by one Legal Department and contracts with customers.
ESSENTIAL CATEGORIES OF PERSONAL DATA SUBJECTS THAT WE PROCESS
– job candidates;
– temporary employees hired under the provisions of the Act on the Employment of Temporary Employees;
– external employees performing work or services at the Customer’s premises;
– WADO internal employees;
– users of this website;
– employees or associates of our Customers or Suppliers.
PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
Users’ personal data may be processed:
(a) for the purpose of contact, i.e. to answer the questions asked by the User via the contact form and to obtain information about the Joint Controllers’ offer – in this case, the processing of data by the Joint Controllers takes place based on the User’s consent (Article 6(1)(a) GDPR);
(b) for the purposes of the Joint Controllers’ legitimate interests related to the operation of the website, including analysing the User’s use of the website (Article 6(1)(f) GDPR);
(c) in order to pursue the legitimate interests of the Joint Controllers, which may include, but are not limited to, establishing, asserting and defending claims, preventing crimes and conducting related investigations, ensuring accountability in accordance with the GDPR, managing and further developing business operations, including risk management (Article 6(1)(f) GDPR);
(d) for the purposes of direct marketing of the Joint Controllers, including the selection of services to meet the needs of Users (including profiling) based on cookies and other similar technologies, as referred to in point 9 – in this case, the processing of data by the Joint Controllers takes place based on the legitimate interest of the Joint Controllers (Article 6(1)(f) GDPR);
(e) for marketing purposes of the Joint Controllers, carried out in particular through the newsletter service, resulting from the consent given by the User (Article 6(1)(a) GDPR);
(f) in order to conduct the recruitment process based on the consent of job candidates and employees to the processing of personal data – Article 6(1)(a) GDPR, Article 9(2)(a) GDPR;
(g) for the purpose of entering into a contract, performance of the contract and execution of the contract – Article 6(1)(b) GDPR;
(h) for the purpose of fulfilling the legal obligations of the employing entity, arising in particular from the provisions of labour law and the obligations of the temporary employment agency under the provisions of the Act on the Employment of Temporary Employees – Article 6(1)(c) GDPR.
RIGHTS OF DATA SUBJECTS
We would like to inform you that all Data Subjects whose data we obtain directly have the right (depending on the legal basis of the processing) to withdraw their consent to the processing of personal data, the right to demand from WADO access to their personal data, rectification, erasure or restriction of processing, as well as the right to object to the processing and, in the case of Data Subjects whose data we obtained directly from Data Subjects, also the right to data portability.
Please be advised that you can withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out beforehand. For evidence purposes, please withdraw your consents in writing by sending a letter to the registered seat address or via e-mail.
Exercise of the above-mentioned rights is possible through the form available on the Application Support Portal (click). For those who do not use the Internet, WADO provide the option of making a request by e-mail: ul. Prosta 68, 00-838, Warsaw or by submitting the request in person at the head office or any WADO branch.
Data Subjects also have the right to lodge a complaint with the supervisory authority (UODO [Office for Personal Data Protection], ul. Stawki 2, 00-193 Warsaw).
We also inform that:
– automated decisions (decisions without significant human involvement) will not be made with respect to Data Subjects, and, generally, personal data of Data Subjects will not be subject to profiling by WADO.
– in case the processing of personal data violates applicable laws, all Data Subjects have the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection.
TRANSFER OF DATA TO THIRD COUNTRIES
As a general rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the countries of the European Union and Iceland, Norway and Liechtenstein. Your personal data may be transferred to the United Kingdom of Great Britain and Northern Ireland, against which, on 28 June 2021 the European Commission issued a decision finding an adequate level of protection for personal data.
In some cases, particularly in connection with the implementation of cooperation with IT solution providers or the need to transfer data to a potential employer, your personal data may be transferred to other third countries. In this case, the personal data safeguards referred to in Articles 46–49 GDPR, such as standard data protection clauses adopted by the European Commission, will be applied.
RECIPIENTS OF PERSONAL DATA
We may transfer personal data, depending on the purpose and legal basis, in part or in whole to other entities. Recipients of personal data are most often:
– WADO’s customers, including primarily job seekers;
– service providers – entities that process data on our behalf and according to our instructions and for a purpose that is strictly defined by us;
– infrastructure, IT, technical and maintenance service providers;
– benefit providers;
– public institutions – to which data is transferred on the basis of the law;
– audit firms, tax consultants, law firms and others.
RETENTION PERIOD FOR PERSONAL DATA
The Joint Controllers process the User’s personal data in the manner and for the period of time that is necessary to fulfil the purposes for which the data was collected.
In the case of data processing:
(a) based on the User’s consent – the User’s data will be processed until the consent is withdrawn;
(b) in order to ensure compliance with legal obligations imposed on the Joint Controllers – the User’s data will be processed for the period required by law;
(c) for the purposes of direct marketing of the Joint Controllers, including selection of services to meet the needs of the User (profiling) – the User’s data will be processed until the User raises an objection or withdraws consent;
(d) for the purpose of concluding, performing, executing a contract – until the termination of cooperation and the expiration of limitation periods;
(e) for the purposes of realisation of other legitimate interests of the Joint Controllers – data will be processed until the realisation of the WADO’s legitimate interests or consideration of an objection raised by the User or the expiration of the period of limitation of claims.
In the case of recruitment processes, the retention period of personal data in our organisation has been set for a period of 1 month from the date of completion of the ongoing recruitment, and in the case of consent to process data for future recruitments – for a period of up to 3 years from the submission of the application or until the withdrawal of consent to processing, whichever occurs first.
Once the recruitment process has been completed, the data may be kept for the period necessary for the purposes of establishing, asserting and defending claims, which constitutes a legitimate interest of WADO within the meaning of Article 6(1)(f) GDPR.
For personal data processed under the law, WADO shall apply a retention period in accordance with applicable laws.
In the case of data processed for WADO’s legitimate interest outside the contractual relationship, we process the data for as long as we have a legitimate interest.
DATA PROTECTION OFFICER
We take the protection of personal data very seriously, which is why in the course of our activities as WADO (by an appropriate resolution as each company) we have appointed a single, joint Data Protection Officer, who can be contacted by e-mail: [email protected], by mail: ul. Prosta 68, 00-838, Warsaw and through the form available on the Application Service Portal (click).
