ASSOCIATES, PRIVACY INFORMATION STATEMENT

Welcome to Adecco. We look forward to working with you to help you to further develop your career. As you’d expect, to properly perform our services, we collect and use information about you.

Adecco is committed to protecting and respecting your privacy. This Privacy Information Statement ‘Statement’ describes your privacy rights in relation to the information about you that we process, as well as the steps we take to protect your privacy. lease read this Statement carefully. There is an index below so you can go straight to the bits you want if you prefer.

Index

First, we need to be clear about how we use some words in this statement.

In this Statement you will be referred to as « You ».

When we talk about ‘us’ or the ‘Company’ we mean Adecco Luxembourg S.A. having its registered office at 5 rue des Mérovingiens Z.AI. Bourmicht, L-8070 Bertrange .
The Company is part of the Adecco Group, the largest HR services provider in the world. Through its various companies and business lines the Adecco Group provides several HR (Human Resources) activities like staffing, secondment, payroll services, recruitment & selection, testing solutions, career transition, talent development, training & education, outplacement and international mobility (‘our Activities’’).
To carry out our Activities the Company uses several IT systems. In some cases, the Company provides a Self-Service Portal (‘Portal’) for its candidates/personnel. The Portal allows you to update your own records such as your contact details and bank details, and where you work for one of our clients, the hours that you have worked.
Finally, this is a statement about information about people – like you and your family. It includes facts about you, but also opinions about you and that you hold (“I’m a football fan” for example). It’s not about information about the Company (although sometimes the two overlap). This type of information is sometimes called ‘Personal information’, ‘Personally Identifiable Information’ or ‘PII’. We use the term ‘Personal Information’ in this statement.

Personal information that the company usually collects includes, but is not limited to

  • your name, date and place of birth, contact details and qualifications (education, training courses and internships), and any other information you mentioned on your resume or CV;
  • if you log on to the Portal using your LinkedIn or any other social media account: your profile data;
  • if you contact us, we will keep a record of our correspondence;
  • feedback about you from our staff and third parties who you work with or for, and other appraisal information; where you give feedback on others
  • your feedback about us and our services through our satisfaction surveys;
  • feedback about you from our staff and third parties who you work with or for, and other appraisal information; where you give feedback on others. As such, we would like to inform you that background checks can be made with your former employers. The decision to carry out these checks will depend on the nature of the positions to be filled and / or the specific of the Clients. These checks are carried out in strict compliance with the legal framework and are limited to information that is directly related to the proposed job or to the professional skills to be assessed;
  • we also collect information on your use of our systems including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make our systems easier to use in the future;
  • details of any declared disabilities and any accommodations we may need to make for you in the workplace;
  • when you start working for the company we shall also collect:
    • your gender, nationality, copy ID documents, proof of address and copies of documents evidencing your right to work in the locations you will work in (visas, work permits, etc.);
    • payroll information such as your bank account information, national insurance or social security number, tax card and reference numbers, your fees, salary and benefits information and any voluntary deductions you ask us to make from your salary and fees );
    • records of your sick leaves, time spent on, training, investigations and disciplinary matters;
    • information about your use of our IT systems and premises (door entry systems);
    • details about your dependents and next of kin;
    • travel information (travel data, credit card information, passport number, expenses incurred) for the purposes of the negotiation, arrangement and purchasing of all travel related activities (e.g. Airfare, Train, Hotel & Car Rental reservations) and the reimbursement of travel expenses;
    • photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed);
    • details of any disability and any accommodations we may need to male for you in the workplace, and
    • in some cases, we will also collect other “sensitive” data than only details related to disability, when are permitted to do so by law.
      • Medical visit (provision of health care services)
      • Record of accidents at work or occupational diseases.
      • Pension fund.

The company collects and processes personal information:

1. To provide you with the assistance you expect, like:

  • Help you to find an assignment in adequacy with your skills,
  • Evaluation of your skills,
  • Integrating in our training plan,
  • Establish your payslip and make the mandatory declarations.

2. to further develop and improve our systems/processes; this takes place in the context of new IT systems and processes, so that information about you will be used in the testing of those new IT systems and processes where dummy data can fully replicate the operation of that new IT system;

3. to perform studies and statistical and analytical research

4. to transfer data to third parties (see below);

5. where necessary, to comply with any legal obligation;

6. when you start working for the Company, to perform our duties to you as your employer; and

7. when you start working for the company:

  • to comply with your contract of employment, and all other contracts and rules that govern our employment or other contractual relationship with you;
  • maintain and improve administration of talent generally (including for the purposes of workforce analysis);
  • carry out other human resources activities (including work management, absence management, training/people management, expense management, and disciplinary procedures);
  • manage shares and other assets to which you may be entitled;
  • promote the security and protection of people, premises, systems and assets;
  • monitor compliance with internal policies and procedures; < /li>
  • administer communications and other systems used by the Adecco Group (including internal contact databases); < /li>
  • investigate or respond to internal incidents and complaints;
  • in the case of photos or videos of training sessions, to report internally that the training sessions have taken place and their content (for example in internal updates) and also to market similar sessions internally and to third parties; or
  • participate in any potential or actual purchase or sale, or joint venture, of all or part of a business or company, that any member of the Adecco Group wishes to participate in.

We are required by law to have a ground set out in the law to process the information we hold about you. The legal grounds can be:

  • Performing a contract or taking steps prior to entering a contract
    When you are already working with or about to engage through Adecco, our processing of personal information for all these purposes is based on processing grounds like the performance of a contract, or about to enter into a contract (purposes 1, 6 and 7 above). These services can be such as providing you with suitable jobs to apply for or helping and assisting you with training and the application process.
  • Compliance with legal obligations
    Sometimes the processing is necessary to comply with legal or regulatory obligations (purpose 6-). Public authorities, such as tax, finance or data protection authorities may request personal data from us and provide us with a statutory reason to disclose information about you (e.g. the prevention or detection of a crime). In these circumstances, we are forced by law to provide the authorities with your data.
  • Fulfilment of our legitimate interest
    The processing is necessary in the legitimate interests of Adecco in exercising its and its staff fundamental rights to run a business in a way which does not unduly affect your interests or fundamental rights and freedoms (purposes 1,3-5 and 7 above). This means that when processing is necessary for the legitimate interests of Adecco, we balance your interests or fundamental rights and freedoms against our legitimate interest in processing. This ensures that we are not processing data in a manner that your interest and fundamental rights override our interest in such processing.
    We shall only process your personal information other than on these grounds with your consent, which is a further processing ground.

The provision of your personal information is a requirement necessary to enter and/or maintain our contract with you. This means that you are obliged to provide your personal information to Us.

If you do not provide your personal information to us, we will either not be able to conduct the employment relationship with you or, at least, you may not be able to participate in certain processes such as feedback or career development (which may also not be in line with your contract with us).

The Company uses automated systems/processes and automated decision-making (like profiling) to provide you, and our clients, with the services you request from us. For example, when our clients are looking for candidates for jobs, we can conduct a search of our lists of candidates using automated criteria to compile a shortlist.

The Company can (and in some circumstances must, depending on the type of data) keep your data for several years after your employment with us has ended. Generally, we retain data concerning taxes and your contract of employment, financial information (including payroll data and data relating to pay, etc.) for 10 years, and other personal information for 3 years. We retain sensitive personal data for no longer than is reasonably necessary.

As mentioned above, we usually disclose your data to third parties. This is done to complete the purposes set out above. We do this in the following circumstances:

  • To our suppliers. We can, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; these suppliers are typically IT suppliers (who host or support our IT systems, including information about you), premises management companies (who look after physical security at our buildings, and therefore need to know about you to allow access to our buildings), HR related providers (who operate payroll or benefits provision on our behalf, such as on site catering for associates and colleagues), travel providers (who manage or organise travel for our associates and colleagues) or back office finance and accounting management providers (who need to handle details of colleagues and associates in order to process accounts payable and receivable) .
  • To members of the Adecco group of companies in other countries. These are located in- or outside the European Union; different members of the group fulfil different functions and as result your information will be shared with them for different reasons:
    • information is shared with members of the Adecco group that provide IT functions for the Adecco companies world-wide; those IT functions are located in France, Prague and Amsterdam
    • information is shared with the head office of the Adecco group in Switzerland for work force planning, budgeting and feedback purposes; this information is also used at head office in Switzerland to propose new opportunities to you within the Adecco group or with clients.
    • information is also shared with Adecco affiliates world-wide where you have expressed an interest in opportunities in that market, or members of the Adecco Group identify that you may have particular skills required or helpful in that market. A list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.adecco.com
  • To our clients/prospective employers: we will share your data with clients of ours who are offering jobs/assignments you may be interested in, or who are interested in your profile, for colleagues this includes where you are working on-site with our clients. They owe contractual and other confidentiality obligations in relation to your data to us, and to you;
  • We will share your data with government, police, regulators or law enforcement agencies (STATEC) if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so; and
  • As part of due diligence relating to (or implementation of) a merger, acquisition, change in service provider or other business transaction we can disclose your data to the prospective seller or buyer, new service provider and their advisers.

Your data can be transferred and processed in one or more other countries, in- or outside the European Union. A full list of the countries in which we operate is available in the ‘choose your country’ function of our website at « Choisissez votre pays » de notre site www.adecco.com.www.adecco.com.

We shall only transfer your data outside the EU to countries which the European Commission believes offers an adequate level of protection to you (a list of those countries is available here:https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_), or where the Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of your information (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

  • Right to access and obtain a copy of your personal information
    You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you have the right to access to your personal information and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information. If there is a self-service system, we really encourage you to access to it and update it yourself. In some limited circumstances, you also have the right to request portability of your personal information, which means, we will provide them to a third party upon your request
  • Right to correct your personal information
    If you can demonstrate that personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected. If there is a self-service system, we really encourage you to access to it and update it yourself.
  • Right to delete/right to be forgotten
    If we do not need to retain or process the data for any other reason, you can request that we stop or restrict the processing or delete (some or all of) your personal information.
  • Right to restrict
    In certain circumstances, you have the right to restrict the processing of your Personal Data. However, in some instances such restriction of processing may limit the Services that you can receive from us.
  • Right to object
    As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.
    If you want to exercise any of your rights, please email us at privacy@adecco.lu. When you email us to exercise your rights, the Company will need you to identify yourself before actioning your request.
    Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

To the extent permitted by law, Adecco reserves the right to audit, monitor and record the access, use and content of any data held or processed by its IT systems. We do this for the purposes (e)-(h) set out above but call this point out specifically in this notice so that you are aware in particular that your use of work related IT systems can be monitored by others.

You are responsible for keeping your login details to Adecco’s systems safe, in particular the password that we have given you or that you have chosen. These login credentials are for your own use. You are not permitted to share your credentials or other account details with any other person(s).

If you have any questions or concerns regarding this privacy information statement would like further information about how we protect your information (for example when we transfer it outside Europe) and/or when you want to contact the company’s Data Protection Officer (DPO), please email us at adecco.globalprivacy@adecco.com. You can also contact the local privacy lead at privacy@adecco.lu.

The terms of this Statement may change from time to time. We shall publish any material changes to this Statement through appropriate notices either on this website or contacting you using other communication channels.