ManpowerGroup’s Personal Information Statement
I. PURPOSES
The purpose of this statement is to outline the basic practices and procedures of ManpowerGroup relating to the collection, disclosure, use and safeguarding of personal information.
II. STATEMENT POLICY
a) The nature of our business operations
ManpowerGroup is a world leader in the employment services industry, providing workforce management services and solutions to clients in over 80 countries throughout the world. Our organization annually provides employment to over four million people worldwide and is an industry leader in employee assessment and training. In North America, ManpowerGroup staffing services include administrative, industrial and contact center personnel as well as the assignment of contract or permanent placement of professionals in information technology, scientific, finance and other professional areas under the ManpowerGroup Professional Brand.
As can be appreciated, ManpowerGroup is a unique organization in that the very services we provide to both clients and to prospective and current employees includes the exchange of personal information for the benefit of all parties involved.
As a result, it is both required and expected by clients and prospective and current employees of ManpowerGroup and its franchises (hereinafter "ManpowerGroup") that personal information will be collected, used and disclosed in a variety of different ways and through a number of different mechanisms.
b) Our philosophy regarding Personal Information
ManpowerGroup respects the privacy of personal information in all aspects of our business. We want everyone to know that we are responsible for the privacy of personal information of a variety of persons throughout the course of the services we provide. In this regard, we have specifically designated a Chief Privacy Officer ("CPO") who is accountable for compliance with the procedures and principles that will be explained in this Personal Information Statement. This statement is designed to formalize our existing practices regarding the collection, disclosure, use and safeguarding of personal information.
III. DEFINITIONS
In this statement,
"Act" means the Civil Code of Quebec or the British Columbia Personal Information Protection Act or the Alberta Personal Information Protection Act and/or the Personal Information Protection and Electronic Documents Act, where applicable;
"collect" means to gather, receive or record personal information about a person from any source and by any lawful method;
"consent" means the voluntary agreement with the collection, use and disclosure of personal information for authorized purposes. Consent can be either express or implied and can be provided directly by the person or by an authorized representative. Express consent can be given orally, electronically or in writing, and is your firm authorization. Implied consent is a common sense conclusion that consent has been obtained from a person's action or inaction.
"disclose" means to making personal information available to a third party;
"person" or "persons" means a natural person and is defined as a former and current prospective temporary candidate, associate, prospective salaried candidate, salaried employee, prospective permanent placement candidate, a permanently placed candidate, a prospective independent contractor, an independent contractor, a prospective subcontractor or a subcontractor as defined in this statement below.
"prospective temporary candidate" means a person who has contacted or provided information to ManpowerGroup with an interest in temporary work with ManpowerGroup's clients but is not an employee with ManpowerGroup or any of its clients.
"associate" means a person who is an employee of ManpowerGroup and who has been placed in a temporary assignment with one of ManpowerGroup's clients but remains a ManpowerGroup employee.
"former associate" means a person who was an employee and placed in a temporary assignment with one of ManpowerGroup's clients but is no longer an employee.
"prospective salaried candidate" means a person who is in contact with ManpowerGroup with a view to obtaining a salaried position with and performing work for ManpowerGroup.
"salaried employee" means a person who has accepted a salaried position with and is an employee who is performing work for ManpowerGroup.
"prospective permanent placement candidate" means a person who is in contact with ManpowerGroup with a view to being placed in a permanent position with one of ManpowerGroup's clients but is not an employee with ManpowerGroup or any of its clients.
"permanently placed candidate" means a person who has been permanently placed as an employee with one of ManpowerGroup's clients and is not an employee of ManpowerGroup.
"prospective independent contractor" means a person who has applied for an independent contracting position but has not been engaged in that position.
"independent contractor" means a person who has been engaged in an independent contracting position.
"personal information" means any information about an identifiable individual but does not include:
• An employee's name;
• An employee's job title;
• ManpowerGroup's business address; and
• ManpowerGroup's telephone number.
For individuals in Quebec, personal information means any information that relates to an individual and allows that individual to be identified.
"third party" means a person or organization outside of ManpowerGroup, its parent, subsidiary and affiliated corporations, including its affiliated brand companies, Right Management, Jefferson Wells, Elan IT and Brook Street.
"use" means the treatment and handling of personal information by or on behalf of ManpowerGroup.
IV. WHY YOUR PERSONAL INFORMATION IS COLLECTED, USED, DISCLOSED OR RETAINED
As outlined earlier, based on the nature of our business, we regularly collect, use disclose and retain personal information about persons in order to both provide staffing services to our clients and provide persons with suitable temporary, permanent or contract employment opportunities. In order that all persons are fully informed, we are outlining the purposes for which ManpowerGroup has always collected, used, disclosed and retained personal information.
Thus, the purposes for which ManpowerGroup may collect, use, disclose and retain personal information about persons may include:
• Recruitment and placement such as searching for and assessing the suitability of persons for a particular job, task or
• Negotiating and making offers of employment, contracts, or temporary assignments to selected persons as applicable;
• Verifying a person's identity, their references, their background and their fitness for the position;
• Verifying and understanding a person's skills, qualifications, and preferences;
• Establishing a person's training requirements or career transition measures, including outplacement services and advancement planning;
• Finding the best job or contract opportunities for persons in order to achieve satisfaction in employment, temporary staffing, or contracting arrangements, as applicable, including any additional related services;
• Fulfilling our client's requests for information, including for audit purposes and for the conduct of operations;
• In connection with the administration of ManpowerGroup's employee benefit plans, including but not limited to medical plans (such as to insurers and benefits consultants), pension plans and payments;
• In connection with medical or health matters related to an employee's job requirements as well as illness(es) or injury(s) of an employee that affects their work, including workers compensation claims, disability and benefits claims and occupational health and safety complaints;
• Workforce and risk management and workplace management, including supervising, managing and providing remuneration and compensation to employees and payments to contractors for invoices rendered;
• Recording significant events during the application process, the employment relationship or contracting relationship;
• Monitoring use of ManpowerGroup's property and equipment, including telephone, facsimile, Internet and e-mail use and access;
• Maintaining a safe workplace and administering workplace policies such as anti-harassment and anti-discrimination policies;
• For any post-employment or post-temporary service provision matters, including providing of verbal or written references to prospective employers;
• Complying with the law, regulatory requirements, and court orders;
• Complying with tax requirements;
• For due diligence review purposes in connection with any purchase or sale regarding ManpowerGroup; and
• Assessing and developing ManpowerGroup's business and operations to better service its employees, contractors and clients.
V. WHAT KIND OF PERSONAL INFORMATION DOES MANPOWERGROUP COLLECT AND FROM WHERE IS IT COLLECTED?
The personal information collected by ManpowerGroup about you as a person, as applicable, may include, but is not limited to:
• Your name, your job title, your ManpowerGroup business address and your ManpowerGroup telephone number (in Quebec only);
• Your home address, home telephone number, email address, other contact information, education, skills, training, work experience, employment history and references;
• Your length of service, promotions, transfers, salary, and salary expectations, benefits, perquisites, and other related information;
• Information needed to establish and maintain an employment or placement relationship with the person, such as work history and assignment details, performance information, work and residency permits, time and expense reporting information, and bank account and other information needed for personnel management, including your job objectives and preferences, if applicable;
• Information necessary for the administration of payroll, payment of invoices rendered, group insurance plans and benefit plans such as the person's social insurance number and GST number,
• Your employment, temporary staffing, or contractor records, including performance evaluations, severe allergies or medical conditions which relate to your ability to perform the bona fide duties of your position,
• Information required for security purposes, any information required by law, or any information required to satisfy contractual obligations.
ManpowerGroup may gather personal information about you from a number of sources including:
From you, including from resumes, educational records, references, applications or forms completed by you for employment or temporary staffing arrangements, interviews, face-to-face discussions, job posting boards, assessments, career counseling, skill-sets re-engineering, course or training, telephone communications, e-mail, internet, ManpowerGroup website, ManpowerGroup business partner website and any other means of communications, whether verbal, written or otherwise;
• From third parties through enquiries we make to verify details provided to us in an application, such as references, credit or back ground checks, and certifications;
• Where applicable, from your agents, brokers, lawyers, intermediaries, and representatives as well as from government and other entities;
VI. CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
The knowledge and consent of a person is required for the collection, use, or disclosure of personal information, except where otherwise not required under the Act. As a person, when you applied for or accepted employment, a temporary staffing or permanent placement assignment, or contracting arrangement, you were understood to have provided ManpowerGroup with your implied consent to ManpowerGroup's collection, use, disclosure and retention of your personal information for the purposes identified to you under this statement (see part IV).
In determining the appropriate form of consent, ManpowerGroup will take into account the sensitivity of the personal information and the reasonable expectations of persons.
In the normal course of providing temporary or permanent staffing arrangements, ManpowerGroup will disclose personal information about persons to its clients when there is a potential for a temporary or permanent staffing arrangement. However, ManpowerGroup only provides the personal information required and requested by the client to make an informed decision regarding a person. ManpowerGroup may disclose your personal information to its clients, other ManpowerGroup entities, affiliates, subcontractors, vendors or suppliers who perform services on our behalf and to a purchaser of some or all of ManpowerGroup's business.
You may withdraw your consent at any time, subject to any statutory or contractual exceptions or restrictions and reasonable notice. You should contact ManpowerGroup for more information.
Where your personal information is transferred to a third party for payroll, benefit administration, or other purposes, ManpowerGroup uses contractual arrangements to provide a comparable level of protection of your personal information.
While we will maintain strict security safeguards, you understand that some of your personal information may be located in other provinces of Canada and in other countries in the normal course of our business (including for storage and processing purposes by third parties) and is therefore subject to the laws of those jurisdictions. It is possible that your personal information could be disclosed to other government entities under a lawful order made in those jurisdictions.
VII. MANPOWERGROUP WILL LIMIT THE USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION
Your records are retained to document personal, confidential and business-related information about you and your relationship with ManpowerGroup.
ManpowerGroup will use or disclose your personal information only for the purposes for which it is collected, except with the consent of the person or as required or permitted by law.
ManpowerGroup shall retain personal information only as long as required to satisfy the purposes identified above where possible, to comply with any obligations specified in the Act, or other statutes, to meet any potential obligations, and to protect the interests of ManpowerGroup and its clients.
In British Columbia, ManpowerGroup will retain personal information for at least one year if the personal information was used to make a decision that directly affects the person.
In Alberta only
For the purpose of recruitment, in the event that you are unsuccessful in obtaining a position, you agree that ManpowerGroup shall retain your personal information on its file until such time as ManpowerGroup reasonably deems it unnecessary to retain the personal information. Once your personal information is deemed unnecessary ManpowerGroup will return the personal information to you or destroy the personal information.
ManpowerGroup will be supplying your personal information to its clients for the purposes of recruitment for various positions. In the event that you are unsuccessful in obtaining a position, you agree that ManpowerGroup's clients shall have the authority to retain your personal information on their file until such time as the client deems it unnecessary to retain the personal information. ManpowerGroup will supply your personal information to its client under an agreement that requires the client to return or destroy the personal information once it is reasonably deemed unnecessary.
VIII. MANPOWERGROUP WILL ENSURE THE ACCURACY AND PROTECTION OF YOUR PERSONAL INFORMATION
ManpowerGroup will attempt to keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is used. In this regard, we expect that you will cooperate and provide us with all updated personal information as required.
In addition, whether in electronic or paper-based format, ManpowerGroup maintains strict security systems to safeguard your personal information as is appropriate in respect of the sensitivity of that information.
IX. HOW YOU MAY ACCESS YOUR PERSONAL INFORMATION
Upon request, ManpowerGroup will make specific information about its policies and practices relating to the management of personal information readily available to persons.
You may access your personal information that ManpowerGroup has in its possession, subject to any statutory exceptions or restrictions. To obtain access to your personal information, please make a written request to ManpowerGroup's CPO stating as specifically as possible which personal information you are requesting access to. The CPO will respond to a written request for access in a timely manner in accordance with the provisions of the Act.
Depending on the personal information requested, copies of your personal information not subject to any restrictions may be provided to you upon payment of an administrative fee. In British Columbia, no administrative fee is required.
You shall be able to challenge the accuracy and completeness of the information disclosed and have it amended if appropriate. For more information on the procedures for doing so, please contact CPO as noted below.
X. WHAT YOU CAN DO IF YOU FEEL THIS STATEMENT HAS NOT BEEN FOLLOWED
Formal Resolution Process
a) Filing A Complaint:
If you believe that ManpowerGroup, its agents, and/or its employees have improperly or without authorization collected, used, disclosed or retained personal information about you contrary to this statement, you must make a written complaint to ManpowerGroup's CPO.
Your written complaint should set out in as much detail as possible regarding your concerns and should contain the following information:
• The conduct that you perceive as contrary to this statement.
• The dates of, times and locations where such conduct occurred, including whether there was a single occurrence, numerous incidents and whether such conduct is ongoing.
• A list of any witnesses, if any, to such behaviour.
• The name of the person(s) who engaged in such conduct.
• Any actions that you have taken to address such conduct as well as any response to your actions.
Investigation:
Once a formal written complaint is made, ManpowerGroup will address your concerns. All written complaints will be investigated, as appropriate, in a timely manner.
The respondent will be given an opportunity to respond to your complaint
b) Conclusion of Investigation:
Upon completion of the investigation, you, as the complainant, will be advised of the results of the investigation.
If it is determined that your complaint is valid, appropriate measures shall be taken by ManpowerGroup and you will be advised of such action.
Under this statement, every person has the right to pursue a complaint under this statement without actual or threatened reprisal or retaliation. If you are not satisfied with the response from the CPO, you may have recourse to the Federal Privacy Commissioner, the Quebec Information Access Commission, the Information and Privacy Commissioner of Alberta, or the Information and Privacy Commissioner for British Columbia as applicable.
XI.TYPES OF CONSENT
We accept any of the following as your consent for ManpowerGroup's existing use and future collection, use and disclosure of your personal information for the purposes identified above:
• Your receipt of this Personal Information Statement, unless you advise ManpowerGroup, either orally or in writing, that you do not agree with the terms stated in this Statement, and that you wish to opt out of all or portions of it;
• Your implied consent such as your unrestricted release of information to ManpowerGroup either directly, or through its authorized representatives;
• Your express written or oral consent; or
• Your consent as provided by your authorized representative, such as a legal guardian, lawyer or power of attorney.
XII. CONFLICTS
If there are any inconsistencies or conflicts between this ManpowerGroup Personal Information Statement and that of any other document published by ManpowerGroup, including the employee handbook, then the terms of this statement prevail. If there are any inconsistencies or conflicts between this ManpowerGroup Personal Information Statement and the provisions of any applicable privacy legislation, the terms of the legislation will prevail.
XIII. ADDITIONAL INFORMATION
For more information, to request access or an amendment to your personal information, or to discuss a complaint, please contact the CPO at:
Alberta Chief Privacy Officer - Alberta Franchise
ManpowerGroup Services 2101 Toronto-Dominion
Tower, 10088-102nd Avenue Edmonton, AB T5J 2Z1
All other provinces Chief Privacy Officer
ManpowerGroup, 4950 Yonge Street, Suite 700
Toronto, ON M2N 6K1
HR-001 ManpowerGroup's Personal Information Statement - Rev. 5/16/08