ManpowerGroup Australian Privacy Policy
Effective Date: 1 May 2024
This ManpowerGroup Australian Privacy Policy provides a framework of understanding about the personal data that is collected by ManpowerGroup Global Inc. and its Australian subsidiaries and affiliates listed below (as applicable, hereinafter each separately and/or jointly called the "Data Controller''). Personal data collected by the Data Controller will be controlled and processed in accordance with the terms of this Privacy Policy.
This Privacy Policy applies to (1) our job candidates and recipients of our career services, (2) our associates, who are people we source or place on assignment with one of our clients, or individuals to whom we provide outplacement or career transition services, (3) users of the websites and apps listed here (the "Sites"), and (4) representatives of our business partners, clients and vendors. This Privacy Policy does not apply to our headquarters and country-based staff employees, who are individuals employed by ManpowerGroup and who work directly for ManpowerGroup and not directly for a ManpowerGroup client.
This Privacy Policy describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our privacy practices and to exercise your rights. Our privacy practices conform with the Privacy Act 1988.
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, job candidate or a candidate accessing career or talent management, 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;
gender;
bank account information;
citizenship and work authorisation status;
benefits information;
tax-related information;
information provided by references;
personality, preference and skills data from assessment participation and/or coaching, including personality traits, skills, strengths, motivators, career aspirations, development opportunities; 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 Bullhorn based on the information provided to us or collected by us. 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 Bullhorn.
In addition, we may collect information you provide to us about other individuals, such as information related to emergency contacts.
Data Processing related to Minors
We respect the privacy of children. Our Sites and services are not typically designed for, or targeted to, children. If you are under the age of 14, you should not send any information about yourself or your contact details through our Sites.
If you are a parent or guardian, please contact us if you believe we may have collected information from your child, and we will review and take appropriate action.
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;
processing payments;
managing our business partner, client and vendor relationships (including those providing services to us);
where permitted under law and consistent with this Privacy Policy, to send promotional materials, alerts regarding available positions and other communications;
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).
In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted under law, we use the information described in this Privacy Policy for the following purposes:
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:
a) Technical 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."
b) Profiling Cookies
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:
(i) customising our users' use of our Sites;
(ii) delivering content tailored to our users' interests and the manner in which our users use our Sites; and
(iii) managing our Sites and other aspects of our business.
Third-Party Cookies
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 (https://tools.google.com/dlpage/gaoptout)
Adobe Analytics: adobe.com/privacy/analytics.html#1 (https://www.adobe.com/privacy/marketing-cloud.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/ (http://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.
Artificial Intelligence (AI) / Machine Learning (ML)
A number of the services we offer are enabled with AI, which may include AI/ML. With the assistance of AI, we can connect the right individuals with the best opportunities and get people into work more efficiently or prepare them for the job market more readily.
We perform risk assessments of the AI solutions we use at ManpowerGroup and use human oversight to the fullest extent possible to ensure no automated decisions are made that produce any legal or similarly significant effects on individuals.
If you are receiving a service that includes the use of AI/ML, you should be informed of this in more detail within the privacy notice provided in connection with that particular service.
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
We do not disclose personal data that we collect about you, except as described in this Privacy Policy or in separate notices provided in connection with particular activities. We may share personal data with vendors who perform services on our behalf based on our instructions 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 also may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates or when you have secured a role with that client; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job or to confirm your placement or continued placement, where appropriate.
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
We also may transfer the personal data we collect about you to countries outside of Australia. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your information to other countries, we will protect that data as described in this Privacy Policy and such transfers will be in compliance with applicable law.
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:
a) 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.
b) 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.
c) 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.
d) Right to have the option of not identifying themself, or of using a pseudonym in certain circumstances.
e)Right to opting out of receiving unwanted direct marketing.
f) Right to request that the processing of their Personal Information is restricted in certain circumstances.
g) Right to object to processing of their Personal Information in certain circumstances.
h) Right to request information on the processing activities carried out with their Personal Information.
i) Right to withdraw consent.
If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.
Updates to Our Privacy Policy
This Privacy Policy (including any addenda) may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our Site indicating at the top when it was most recently updated.
Use of Cookies
This website uses cookies to collect information about your browsing session so we can provide the best experience possible. To learn more about what we collect and how we use it, view our Cookie Policy.
ManpowerGroup’s Non-Discrimination Policy
Users of our Sites and services will not be subject to discriminatory treatment for exercising their privacy rights.
Please bear in mind that exercising some rights, like erasure, consent withdrawal or your right to object, may affect our ability to carry out and deliver some, or all, of the services you are eligible for.
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 privacy@au.manpowergroup.com
If you would like to exercise your rights, you can do so by submitting your request through this webform here: Data Subject Request Form
We may charge a reasonable fee for providing that information.
Subsidiaries and Affiliates in Australia to whom this Policy applies
Experis Australia Pty Ltd.
Manpower Services (Australia) Pty. Ltd.
Manpower Staffing (Australia) Pty Limited
Manpower Staffing Holdings (Australia) 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