Privacy Notice

The General Data Protection Regulation (hereinafter “Regulation”) defines personal data as follows: 

Any information relating to an identified or identifiable natural person; ‘identifiable natural person’ means a natural person who can be identified, directly or indirectly, by reference to an identifier, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

When this Privacy Notice refers to Personal Data, it refers to the definition in the Regulation. 

Special categories of personal data

The processing of special categories of personal data means the processing of personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.  

We only process special categories of Personal Data where this is necessary to comply with our legal obligations.

We may collect Personal Data about you in variety of ways, such as through our Sites and social media channels; at our events; through phone; through job applications; in connection with recruitment processes or in connection with our interactions with clients and vendors, whereas categories of personal data collected depend on the nature of the relationship.  

2.1. If you visit our Sites, following types of Personal Data may be collected: 

• Cookie data collected via any non-strictly necessary cookies, if you have provided your consent via the cookie banner on the platform.
• Information you may provide to us through the "Contact Us" feature on our Sites or via email. 

Legal basis is consent.  

Purpose of data collection is to reply to your queries or provide you enhanced functionality and personalization on your visit to the Sites. Please find out more in our Cookie Notice. 

Advertising, Measurement and Remarketing

Where you have provided your consent, we may use cookies and similar technologies to measure the performance of our advertising, improve our digital campaigns and show more relevant advertisements.

For these purposes, we may use services provided by Google and other advertising and analytics partners, including Google Ads and Google Analytics. The personal data processed may include online identifiers, cookie identifiers, IP address information, device and browser information, and information about your interactions with our websites and advertisements.

Your choices in our cookie banner determine whether cookies and similar technologies may be used for advertising, analytics and remarketing purposes. If you do not consent to advertising cookies, the use of cookies and identifiers for personalised advertising and remarketing will be limited. Certain aggregated or modelled measurement may still take place in accordance with applicable legal requirements and your consent settings.

We may share limited information with Google and other providers of advertising and analytics services where this is necessary for the purposes described above and only in accordance with your consent choices and applicable data protection legislation.

The legal basis for this processing is your consent, which may be withdrawn at any time through our cookie preference settings.

Personal data processed through these technologies may be transferred to countries outside the European Economic Area. Where such transfers occur, appropriate safeguards will be implemented in accordance with applicable data protection laws.

Further information about the cookies and similar technologies we use can be found in our Cookie Policy.
 

Google Ads Enhanced Conversions

We also use the Enhanced Conversions feature within Google Ads. Enhanced Conversions is an extension of conversion tracking designed to improve the accuracy of conversion measurement.
As part of this process, certain personal data entered by users on our website may be processed, such as an email address, name, postal address or telephone number, provided that such information is submitted through an application, form submission or other interaction with our website.

Before being transmitted to Google, this information is transformed using a cryptographic hashing process. This means that the directly submitted information is not transmitted to Google in plain text. The hashed data is transferred to Google’s servers in the United States, where Google may compare it with hashed information associated with existing Google accounts to improve the attribution and statistical analysis of conversions resulting from interactions with our Google Ads campaigns.

The purpose of Enhanced Conversions is to provide more accurate measurement of the effectiveness of our advertising activities and to optimise our Google Ads campaigns. The hashed information is used for matching, conversion measurement and advertising optimisation purposes. Hashing helps protect the information during transmission, but the hashed data is still treated as personal data where required under applicable data protection law.

The legal basis for this processing is your consent. You can prevent this processing or withdraw your consent at any time by adjusting your preferences in our consent management platform.

Further information about Enhanced Conversions is available on Google’s help pages.

2.2 If you are a representative of potential or existing business partners, client or vendor, Personal Data collected may include: 

• contact information such as name, postal address, email address and telephone number, job title, company name or any other information which could be on your business card or on your social media profile. 
• Any other information you provide to us through the "Contact Us" feature on our Sites, in surveys or in other form of communication.  

Legal basis for such data processing is legitimate interest of a data controller (Please find out more in the legitimate interest section in this Privacy Notice) or since the processing is necessary for performance of a contract or to take steps at the request of a data subject prior to entering a contract.  

Purpose of data collection is to introduce or deliver our services, respond to your queries or to provide information you have requested.  

Based on your consent, we may use your personal data for example for customer references.  

2.3 If you create an account by registering on our Site, Personal Data collected may include:

• username and password.
• information you upload to your account, for example your curriculum vitae which include your employment and education history, language proficiencies and other work-related skills. 
• information you provide about your referees you would like us to contact (the Controller assumes that the provided referee has given an authorization for such communication).
• Any other information you may provide to us, such as in surveys or in any form of communication (for example via email or phone call). 

Legal basis for such data processing is consent from you, for example, when you tick a box to give permission based on your understanding of the nature of the processing.  

Purpose of data collection is to create, provide access and manage your candidate or Parter account, to be able to assist you in your job search, offer you employment-related opportunities and services if you are a candidate or contractual opportunities if you are a Partner and present you with potential job matches or assignments. You can edit your profile and adjust the optional information you have disclosed to us at any time. 

2.4. If you apply for a position or are a recipient of a career service, following types of Personal Data may be collected:  

• Employment and education history.
• Language proficiencies and other work-related skills.
• Information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment.
• Social Security number, national identifier, or other government-issued identification number.
• Date of birth.
• Citizenship and work authorization status.
• Information provided by references.
• Information you provide to us directly in any form (such as an interview or uploading the information to your profile). 

Legal basis for such data processing is legal obligation, where we must Process the Data because it is required by law, contract or legitimate interest of a data controller for which we have analysed and concluded that our legitimate interest does not pose a high risk to the data subject. Please find out more in the legitimate interest section in this Privacy Notice. 

Purpose of data collection is to assess your suitability for job opportunities, facilitate the recruitment process, contract preparation or fulfilment of controller’s legal obligation to process data.

The Data Controller may process Personal Data for certain legitimate business purposes, which includes all the following: 

• to identify and prevent fraud.
• to enhance security of our network and information systems.
• for marketing purposes.
• to enhance, modify, personalize, or otherwise improve our services, such as utlizing technical measures, e.g. the transcription feature.
• for investigations and dispute resolution.  
• performing data analytics and develop and train artificial intelligence (AI), including machine learning, models.

Whenever we process Personal Data for these purposes, we will ensure that we keep your rights in high regard and take account of these rights. You have the right to object to such processing, and if you wish to do so, please submit your request here.  

We use artificial intelligence (AI) tools strictly as support tools within our recruitment and administrative processes. AI is used solely as a support tool for our recruiters and does not replace human oversight and human assessment. All decisions relating to candidates are made by a human recruiter.

Prior to implementing any AI-supported system, we conduct Data Protection Impact Assessments (DPIAs) to identify and mitigate potential risks to the rights and freedoms of individuals. We regularly review our AI systems to identify and mitigate potential bias and to ensure fair and non-discriminatory outcomes.
 

AI-supported processing and sorting

AI tools may assist in the initial screening of candidates by sorting or ranking applications based on predefined, job-related criteria (such as work authorization, qualifications, or required licenses).
 

We ensure that such AI-supported processing is always subject to human review, does not result in automated decisions, and does not produce legal or similarly significant effects for candidates without human involvement.
 

No automated decision-making

We do not carry out automated decision-making within the meaning of Article 22 GDPR.
All candidate evaluations, shortlisting decisions, and hiring recommendations are reviewed by a recruiter and confirmed through human judgment before any action is taken.
 

Use of personal data and fairness

AI tools may analyse candidate information such as professional experience, qualifications and skills relevant to the role.
 

We do not use special categories of personal data (such as data relating to health, ethnic origin, religion, or similar sensitive data) for screening, ranking, or evaluation purposes.
 

We take appropriate steps to ensure that processing is fair, transparent, and proportionate, criteria used are relevant and non-discriminatory and AI outputs are regularly monitored for bias and accuracy.
 

Use of MS Copilot and Hubert in the processing of candidate personal data

We may use Microsoft Copilot and Hubert to support our recruitment and administrative processes. These tools may assist our recruiters in organizing, summarizing, or retrieving candidate-related information in a secure environment. The use of MS Copilot and Hubert does not involve automated individual decision-making within the meaning of Article 22 of the GDPR. All evaluations, selections, and decisions relating to candidates are always reviewed and confirmed by a human recruiter before any action is taken. Personal data processed via MS Copilot or Hubert is handled in accordance with our technical and organizational measures and is not used for automated profiling or the evaluation of individuals. These tools operate within a secure environment, do not make decisions about candidates, do not perform automated profiling or evaluation, and are used only to support human decision-making. All personal data processed via these tools is protected through our technical and organisational measures.
 

Your rights

You have the right to request human intervention in any process involving AI support, express your point of view, request a manual review of any assessment. You may also request general information about the criteria used in AI-supported screening processes. For more details on how to exercise your rights, please refer to section 9 below.

We maintain technical and organisational measures designed to protect the Personal Data we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.  

Such measures are designed to provide an appropriate level of security taking account, on one hand, the technical state of the art and, on the other hand, the sensitivity of the personal data and the evaluation of potential risks. To provide the appropriate security and confidentiality of Personal Data, we apply to the following non-exhaustive list of measures: 

• Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths.
• Strong user authentication and role-based access controls. 
• Network monitoring solutions with events logging.
• Hardened network infrastructure.
• Measures for ensuring physical security of locations at which personal data are processed.
• Business continuity and disaster recovery plans with periodic testing.
• Incident management policy and processes.
• Periodic vulnerability and penetration testing.
• Certification/assurance of processes and products. 
• Periodic employee privacy and security training and awareness program.
• Third party privacy and security assessments.
• Robust data processing and confidentiality agreements.
• Organizational measures for ensuring data minimization, purpose limitation, retention, data quality and accountability. 

As we cooperate with natural and legal persons in many different jurisdictions, we may need to transfer your Personal Data to countries outside of the country in which the information was originally collected. Some of these countries may not have the same data protection laws as the country in which you initially provided the Personal Data. When such transfers take place, we will protect that data as described in this Privacy Notice.  

If you are in the European Economic Area, Switzerland, or the United Kingdom, we ensure transfers to countries not currently granted adequacy agreements take place only based on: 

1. Standard Contractual Clauses (SCCs) adopted by the European Commission, along with the mandatory adoption provisions required for the UK and Switzerland to the extent the processing involves UK or Swiss residents.
2. A legally binding and enforceable instrument between public authorities or bodies. 
3. Binding corporate rules (BCR).  

Where transfers rely on SCCs, transfers will only take place after a transfer impact assessment is conducted of: 

1. The legal practices of the recipient country relating to access to data; 
2. The technical and organizational measures adopted to protect the data; and
3. The nature of the processing to ensure purpose limitation and data minimization. 

Data Privacy Framework

ManpowerGroup (including ManpowerGroup Global Inc., Right Management LLC and ManpowerGroup Talent Solutions LLC) complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce. ManpowerGroup has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-US DPF. ManpowerGroup has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In the context of onward transfers, ManpowerGroup is accountable for the processing of personal data it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf.  ManpowerGroup remains liable under the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles if ManpowerGroup’s agent processes personal information in a manner inconsistent with the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, unless ManpowerGroup proves that it is not responsible for the event giving rise to damage. 

The Federal Trade Commission has jurisdiction over ManpowerGroup’s compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF. In certain situations, ManpowerGroup may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ManpowerGroup commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact ManpowerGroup using the information provided in the How to Contact Us section of this notice.  

In compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ManpowerGroup commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship. 

For complaints regarding EU-US DPF, the UK Extension to the EU-US DPF, and Swiss-US DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction

We do not disclose Personal Data that we collect about you, except as described in this Privacy Notice or in separate notices provided in connection with activities.  

• Your Personal Data will be shared internally with our team of recruiters, and where applicable, with our clients involved in the recruitment process. 
• We may also disclose a portion of your Personal Data with our subsidiaries and affiliated ManpowerGroup companies for administrative, legal or compliance purposes.
• If you create an account by registering on our Site, apply for a position or are a recipient of a career service, we share your Personal Data with clients who have job opportunities available or interest in placing our job candidates.
• 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 on the following basis: 

• To law enforcement authorities or other government officials based on a lawful disclosure request.
• If we are required to do so by law or legal process. 
• 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; and. 
• We will disclose a portion of your Personal Data with vendors who perform services on our behalf based on our instructions to make our services available to you. We ensure this data is minimized to what is necessary to perform the specific services instructed. We ensure vendor due diligence takes place to assess their privacy and security measures for protecting your data.
• We also ensure that data processing agreements are in place with vendors, with robust requirements stipulating the technical and organizational measure we require them to comply with when handling your personal data.  

We do not authorise vendors to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. Your Personal Data will never be sold, rented, distributed, or made available to vendors for their own commercial purposes, including for their direct marketing purposes.  

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 reorganization, dissolution, or liquidation).

We retain collected Personal Data in our systems in a way that enables data subjects to be identified for no longer than is necessary for the purpose for which the data were collected or for which data are additionally processed. We determine the specific period considering the following: 

• The need to retain collected Personal Data to provide the services requested by the data subject.
• The need to protect the legitimate interests described under the objectives of the controller.
• The existence of specific legal obligations that make the processing and retention of Personal Data necessary for specific periods. 

To comply with applicable statutory retention laws, the data will be kept as follows: 

• If you have created an account by registering on our Site, have applied for a position or a recipient of a career service, the data will be stored until the account owner deletes the information on the account or 2 years after the inactivity, calculated from the last log-in date. 
• If you visit our Sites, your data will be kept as long as stated in the Cookie Notice.
• If you are a representative of a vendor, we will keep information for maximum 10 years after the end of the relationship of the legal entities. 
• If we are providing any type of services to your company, we will keep information for maximum 10 years after the end of the relationship of the legal entities. 

Personal Data may be kept for longer than stated above only if it is required to meet our legal or regulatory responsibilities, for example, establishing, exercising, or defending legal claims or compliance cases.  

When permitted by applicable law, a data subject can exercise under Articles 15 to 22 of the GDPR the following specific rights:  

Right of access: You have the right to know if we process personal data about you, and to receive a copy of the data we process about you. 

Right to rectification: You have the right to request that we rectify inaccurate or incomplete data held about you to protect the accuracy of such information.  

Right to erasure: In some cases, you have the right to ask us to delete personal data about you. For example, if it’s no longer necessary for ManpowerGroup to process the data for the purpose for which we collected it; if you withdraw your consent; if you have objected to the processing and there are no legitimate, overriding justifications for the processing; or if the processing relates to direct marketing and you object to the direct marketing.  

Right to restriction of processing: You have the right to request that the data controller restricts the processing of your data.  

Right to data portability: You can request a copy of the personal data relating to you that we process for the performance of a contract with you, or based on your consent, in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that ManpowerGroup transfers the data directly to the other recipient.  

Right to object: You have the right, at any time, to object to processing of your personal data which is based on our legitimate interest, by referencing your personal circumstances.  

Right not to be subject of automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or similarly significantly affects you, unless it is necessary for entering into contract, is based on your explicit consent, or is authorized by law.  

Right to lodge a complaint with a supervisory authority: You have a right to lodge a complaint with a supervisory authority, in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating you infringes GDPR. 

Whenever the processing is based on consent, as under art.7 of the GDPR, you may withdraw your consent at any time.  

If you require more information about the processing of your Personal Data, please refer to the How to Contact Us section below. You can exercise your data subject rights, by submitting your request here.

This Privacy Notice (including any addenda) may be updated periodically to reflect changes in our privacy practices, to comply with applicable legal updates or to make the information clearer to you. 

We encourage you to frequently check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.   

If we make changes that have a substantial impact on how we process your personal data, we will communicate this on our websites. 

* *Subsidiaries:

Manpower AB
Manpower & Jefferson Wells AB
Manpower Flexjobb AB
ManpowerGroup Solutions AB
Manpower El & Tele AB
Manpower Matching AB
Experis AB
Elan IT Resource AB
ManpowerGroup Solutions IT AB
RightManagement Sweden AB

**Websites: