ManpowerGroup Statement on Personal Data Processing
ManpowerGroup helps organizations transform in a fast-changing world of work by sourcing, assessing, developing and managing the talent that enables them to win. We develop innovative solutions for over 400,000 clients and connect 3+ million people to meaningful sustainable work across a wide range of industries and skills across our expert family of brands – Manpower®, Experis®, Right Management® and ManpowerGroup® Solutions.
Our company’s brand and reputation is best known for its trustworthiness — an attribute that we uphold in all that we do. We put strong ethics and legal compliance at the center of what we do and we’re proud to be consistently named one of the World’s Most Ethical Companies by the Ethisphere Institute and one of Fortune’s Most Admired Companies, confirming our position as the most trusted and admired brand in the industry.
Our clients trust us with their data and we take this trust very seriously. ManpowerGroup acts as data processor on behalf of our clients and is responsible for the protection of personal data in accordance with applicable law.
In this statement we describe the measures that ManpowerGroup takes to assist our clients to comply with applicable legislation, including the EU General Data Protection Regulation (“GDPR”).
General Data Protection Regulation (GDPR)
On the 25th of May 2018, the EU General Data Protection Regulation will come into effect and significant changes will be required by organizations established in the EU (and certain other organizations) that process personal data. GDPR is consistent with our ethical values and corporate principles, and we support the strengthening of data protection laws for companies and individuals in an increasingly data-rich future.
As part of ManpowerGroup’s strategy on GDPR, ManpowerGroup formed a Global Steering Committee to support our global GDPR compliance program. The Steering Committee comprises experts from across our business including data privacy, risk management, operations, IT and information security, supported by subject matter experts from outside of our organization. ManpowerGroup will also leverage market-leading tools to ensure that best practices are implemented.
Additional steps being undertaken as part of the ManpowerGroup GDPR Compliance Program.
• Processing Data. ManpowerGroup may (service dependent) act as a Data Processor on behalf of clients and tiered suppliers.
• Instructions. ManpowerGroup, where acting as a Data Processor, processes Personal Data only in accordance with applicable data protection legislation and client instructions. Our clients may request that copies of data held by ManpowerGroup be returned or destroyed at the end of service delivery, unless retention is required under contract or by law. We trust that our clients inform Data Subjects regarding the processing of their personal data through our services, and otherwise comply with applicable law with respect to the processing.
• Awareness. ManpowerGroup employees receive annual training on both data privacy requirements and security policies. Additional awareness and training is taking place in conjunction with the introduction of GDPR.
• Subcontractors and Third Party Providers. Our services may sometimes require subcontractors and third party providers (“Suppliers”) to help ManpowerGroup fulfill our operational delivery obligations to our clients. ManpowerGroup manages our subcontractors and Suppliers through our supply chain management program. ManpowerGroup ensures that we have appropriate mutual confidentiality and data processing agreements in place with our sub-contractors and Suppliers.
• International Transfer. Where ManpowerGroup transfers personal data outside of the European Economic Area to a country that the EU determines does not have adequate protections in place, ManpowerGroup ensures that data is adequately protected through use of appropriate contractual provisions. ManpowerGroup shall also where required support our clients to ensure that appropriate contractual agreements, including the EU Standard Contract Clauses, are put in place.
• Security. ManpowerGroup engages with external global experts to review and support our ongoing security activities. Additions and modifications to these security standards will be made in order to comply with the GDPR. ManpowerGroup maintains appropriate technical and organizational security measures designed to protect the security and integrity of our systems and personal data we process on your behalf.
• Security Incidents. ManpowerGroup commits to notifying our clients in the unlikely event of any unauthorized access to personal data contained on our systems in compliance with local legal requirements. ManpowerGroup shall, in line with GDPR and local law, cooperate with clients to help them notify breaches to regulators and where required to data subjects. ManpowerGroup will use reasonable efforts to identify and remediate the cause of such a security incident.
• Access. Clients who have received requests from data subjects to amend, rectify, block or erase their personal data, or object to the data processing conducted by ManpowerGroup on their behalf, can seek assistance from ManpowerGroup to help address the request by liaising with their local contacts.
• Assistance. ManpowerGroup will provide further reasonable assistance to our clients in ensuring compliance with their obligations under law, taking into account the nature of the processing and the information available to us.
• Records of Processing. In accordance with GDPR, ManpowerGroup will maintain a record of the categories of personal data processed on behalf of our clients.
• Governance. Our Global Steering Committee consists of data protection and security experts and is responsible for the implementation of our data protection program, as well as identifying and documenting our related data processing activities and performing security and data protection impact assessments.
If you have any questions please speak with your local ManpowerGroup team who will connect you with the appropriate ManpowerGroup data privacy team.
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