Confidentiality agreement

Manpower’s global privacy principles

As of July 23rd, 2018

Manpower has long recognised the importance of maintaining the privacy of the sensitive information of our employees, candidates, clients, suppliers and partners. The nature of our business requires us to collect and handle sensitive information, and we have a responsibility to protect this information for as long as it is in our possession.

Manpower observes Swiss and European data protection legislation within its scope of application. This privacy notice provides the information required to understand how we collect, use and manage the personal data of the natural persons concerned.

In case of doubt, the French version of our privacy notice shall be legally binding.

Data Controller

Your data is processed by Manpower SA (“we/us”, “Manpower”), which is entered in the commercial register of Morges and is the Data Controller. However, we also call on subcontractors to delegate some of the processing, and this document describes the measures taken to guarantee the security of your personal data in this specific case too.

This privacy notice applies to the personal data of all natural persons using our services (“you”):

  • users of our websites and apps (the list is published here, whether or not they have a personal account;

  • people we are looking to place (our Candidates and Temporary Workers);

  • our contacts with our clients, suppliers and business partners;

  • and people who subscribe to our communications and newsletters.

This privacy notice also describes

  • the types of personal data we collect and process,

  • how we process and protect this information, how long we store it,

  • with whom we share it,

  • and what your rights are regarding your personal data, and how you can exercise them.

What data do we collect?

It depends on the nature of our relationship.

Most of the time, we record your contact information such as your name, postal address, e-mail address and telephone numbers.

As a user of our websites and apps, we record information about your usage (IP address, date and time, service requested, etc.) and we also store cookies. If you have a personal account, we store the necessary information such as your username and password. To find out more about this, please consult the Terms and Conditions and our Cookie Policy for each site or app.

If you ask us to provide services, such as a placement with one of our clients, we also record the information required, which is generally included in a CV, such as:

  • your date of birth, gender, nationality and permanent residence permit

  • your professional qualifications; your education and employment history; your language, IT and other skills; your career interests or any other information about your qualifications for employment

  • if you provide them, your photo and extracts from the register of convictions and debt enforcement register

If we also hire you as a Temporary Worker with one of our clients, we record administrative and financial information such as:

  • your bank details, your OASI number (social security) and the information on a form of identification;

  • contract, salary, tax or other information required to manage your contract, which also enables us to fulfil our obligations as your employer;

  • if you provide them, the contact details of people to contact in case of an emergency.

Please note that your application may also contain sensitive data pursuant to Art. 3 letter c of the Swiss Federal Data Protection Act (FADP) or special categories of personal data pursuant to Art. 9 of the EU General Data Protection Regulation. For example, this may include data about political opinions, religious beliefs, physical or mental health or a photo showing your ethnic origin. If you provide such information in your application, you expressly accept that we may store, process and transfer this information.

How do we use this information?

All our processing is carried out on a legal basis and falls into (at least) one of the following categories:

  • your consent, or your explicit consent

  • compliance with a legal, regulatory or contractual requirement (such as ensuring the processing of your salary or social security contributions)

  • our legitimate interests, which are described in the next section

We use your personal details to:

  • create and manage your accounts on our sites and apps

  • manage our contracts with you, including processing and paying salaries

  • manage our client and supplier relationships

  • provide services such as sending you promotional material, newsletters or vacancy alerts in accordance with the terms and conditions of our websites

  • carry out direct marketing campaigns such as promotions, offers, surveys, competitions, newsletters, market research or special events

  • respond to your enquiries and complaints

  • operate, evaluate and improve our business (including analysing, enhancing and developing our services; managing our communications; performing data analytics and performing internal functions such as accounting, etc.)

  • protect ourselves against fraud and other illegal activities by trying to identify and prevent them, as well as in the case of debt enforcement or other complaints and

  • comply with applicable legal requirements, relevant industry standards, our contractual obligations and our internal policies

In addition to the activities listed above, if you are a Candidate or Temporary Worker and you have an account on our websites or have applied for a position through us, we also use your personal data to:

  • assess your suitability and qualifications as a Candidate for a job

  • offer you job opportunities and work

  • provide HR services to you, including benefits programmes, induction, payroll, performance management and disciplinary actions

  • provide additional services to you, such as training, career counselling and career transition services

  • perform data analytics, such as analysing our Candidate and Temporary Worker base; assessing individual performance and capabilities, including scoring on work-related skills; identifying skill shortages; using information to match individuals and potential job opportunities and analysing pipeline data (trends regarding hiring practices)

We may also use your information for other purposes, for which we provide specific notice at the time of collection at the latest, or with your consent.

What are our legitimate interests?

As a Data Controller, Manpower may process personal information for legitimate business purposes, which include:

  • analysing, enhancing, developing or modifying our services in general;

  • identifying and preventing fraud;

  • enhancing the security of our network and information systems;

  • better understanding how people interact with our websites;

  • direct marketing purposes, as well as determining the effectiveness of our promotional and advertising campaigns;

  • sending postal communications which we think will be of interest to you.

Whenever we process data for these purposes, we will take care to ensure that we respect your rights and take them into account. You have the right to object to such processing. To find out how to exercise this right, please refer to the How to exercise your rights section below.

How long do we store your personal data?

We keep personal data in our systems for the time period necessary for our processes and to comply with our legal obligations. We determine this specific period of time by taking into account:

  • the need to keep the data in order to offer the services agreed with you

  • our legitimate interests as described in this document

  • observing our legal obligations, for example as an employer to our Temporary Workers

What information do we share?

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

We may share your personal data with our suppliers who perform services on our behalf based on our instructions. We have obliged our suppliers to process your data confidentially and do not authorise these suppliers to use or disclose your personal data except to provide these services on our behalf or to comply with legal requirements. We may also share your personal data (i) with our affiliates; (ii) if you are a Candidate for a job, with clients who may have job opportunities available and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

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 based on a lawful disclosure request and (iii) when we believe disclosure is appropriate to prevent physical injury, damage or financial loss, or in connection with an investigation of suspected fraudulent or illegal activity.

We also reserve the right to transfer your personal data in the event we sell all or a portion of our business or assets (including in the event of a restructure, dissolution or liquidation).

Do we transfer your data to another country?

We may transfer your personal data outside Switzerland to the countries of the European Union (subject to the EU General Data Protection Regulation) or to other countries. When we transfer your personal data to countries without an equivalent level of data protection to that of the EU or Switzerland, we make sure to obtain the guarantees required to adequately protect your personal data. Specifically, we apply the guidelines of the Swiss Federal Data Protection and Information Commissioner.

What are your rights?

The legal framework gives you a number of rights regarding your personal data. You can exercise several of these rights independently using your MyManpower account. Your main rights specifically include:

  • Right of access and right to rectification: you have the right to access your personal data in order to verify that it is processed in accordance with the law. You also have the right to request the rectification or completion of your personal data in order to ensure the accuracy of its processing.

  • Right to erasure (“right to be forgotten”) and right to restriction of processing: You have the right to ask us to erase your personal data or to stop processing it if we are unable to erase it.

  • Right to object: you have the right to object at any time to our processing of your personal data for reasons stipulated by law without needing to justify your decision.

  • Right to object to automated individual decision-making: also includes profiling, and typically governs the use of cookies.

Whenever the processing is based on your consent, you have the right to withdraw your consent at any time with effect for the future.

To exercise your rights regarding the processing of your personal data, please refer to the How to exercise your rights section below.

Updates to our privacy notice

This privacy notice (including any addenda) may be updated at any time to reflect changes in our privacy practices or legal updates. For significant changes, we will endeavour to notify you, specifically by posting a message on our website. We always recommend that you check the version of this notice; the version published on our website is authoritative.

How to exercise your rights

To exercise your rights or request the erasure of your data:

  • When you log in to your MyManpower account, you can decide if you wish to be contacted, manage your alerts or ask for your account to be erased.

  • If you do not have an account, we strongly encourage you to create one so that you can use it to manage your privacy options.

  • If, however, you do not wish to create a MyManpower account, you can send an e-mail to [email protected]

Please bear in mind that, if you exercise your right to object, this may affect our ability to carry out and deliver services to you for your benefit.

How to contact us

If you have any questions or comments about this privacy notice or our data processing, please write to:

Data Protection Officer

Manpower SA

Rue du Sablon 2

1110 Morges – Switzerland

E-mail: [email protected]