Notice at Collection for California Associates and Consultants
Effective January 2023
Your employer (the "Company") is providing this Notice at Collection for California Associates and Consultants ("Notice"), as a supplement to the Company’s Global Privacy Notice, to inform you about the following:
- the categories of Personal Information that the Company collects about Associates and Consultants (our employees who are placed on temporary assignments with our clients) who reside in California;
- the purposes for which the Company uses that Personal Information;
- whether the Company sells or shares that Personal Information; and
- the length of time the Company intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period (provided that Company shall not retain your Personal Information for each disclosed purpose for which the information was collected for longer than is reasonably necessary for that disclosed purpose).
For purposes of this Notice:
- "Company" means the ManpowerGroup entity that is your employer of record (Manpower, Inc./California Peninsula; ManpowerGroup Public Sector Inc.; Experis US LLC; or Manpower US Inc.).
- "Personal Information" means information that is not publicly available and identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its employees, who reside in California, in their capacity as the Company’s employees.
- "Share" or "Sharing" means the disclosure of Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Assistance For Disabled Employees
Alternative formats of this Notice are available to individuals with a disability. Please contact [email protected] for assistance.
Identifiers and Professional or Employment-Related Information
1. Personal Information Collected: The Company may collect identifiers and professional or employment-related information, including the following:
Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, Social Security Number, signature, online identifier, Internet Protocol address, bank account name and number for direct deposits, driver’s license number or state identification card number, passport number, credit card number, and debit card number.
Professional or Employment-Related Information: compensation, bonuses, equity grants, pensions, benefits, attendance, evaluations, performance reviews, discipline, personnel files, expenses, education, corporate credit card details, membership in professional organizations, professional certifications, work eligibility in order to comply with legal requirements, and current and past employment history.
2. Purposes of Use:
| Managing Personnel: | |
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| Monitoring, Security, and Compliance: | |
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| Conducting Our Business: | |
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Personal Information Categories From Cal. Civ. Code § 1798.80(e)
The Company may collect categories of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in "Identifiers," above) as follows for the purposes listed below:
- Photograph and physical description: (a) for security and internal identification purposes, and (b) to identify employees to co-workers, prospective and current customers, and other third parties.
- Medical information: (a) to the extent necessary to comply with the Company’s legal obligations, such as to accommodate disabilities; (b) to conduct a direct threat analysis in accordance with the Americans with Disabilities Act; (c) for workers’ compensation purposes; (d) for occupational health surveillance; (e) for occupational health and safety compliance and record-keeping; (f) to conduct fitness-for-duty examinations; (g) to administer leaves of absence and sick time; and (h) to respond to an employee’s medical emergency.
- Benefits information: to administer short- and long-term disability benefits
Characteristics of Protected Classifications Under California or Federal Law
The Company may collect information about race, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including contractual obligations to Company clients.
The Company may also collect the following characteristics (in addition to those listed above) as necessary for the purposes described below:
(a) religion (includes dress and grooming practices and encompasses all aspects of religious belief, observance and practice);
(b) sex (includes gender, pregnancy, childbirth, breastfeeding, or related medical conditions; also, sexual orientation);
(c) disability;
(d) national origin;
(e) military and veteran status;
(f) marital status;
(g) age; and
(h) familial status.
The Company uses this Personal Information for purposes including: disability, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary to comply with the Family Medical Leave Act and California law; military and veteran status as necessary to comply with leave requirements under applicable law and for tax purposes; age incidentally to the use of birth date for birthday celebrations and identity verification; religion and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary for accommodations under applicable law; national origin as necessary to comply with immigration laws; and marital status and familial status as necessary to provide benefits and for tax purposes.
The Company collects this category of Personal Information on a purely voluntary basis and uses the information only in compliance with applicable laws and regulations.
Biometric Information
- Personal Information Collected: The Company may collect biometric information, including the following: fingerprints; face imagery and faceprints.
- Purposes of Use: to conduct criminal history background checks when required for certain sensitive positions; to record time worked using a facial recognition time clock.
Commercial Information
- Personal Information Collected: The Company may collect commercial information including the following: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Purposes of Use: reimbursement of business expenses, auditing, data security, preventing illicit activity, providing services, research and development, error prevention, quality assurance and improvement, product and service training, order fulfillment, and marketing/advertising.
Education Information
- Personal Information Collected: The Company may collect education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
- Purposes of Use: to determine suitability for internal roles and promotions, to determine eligibility for training courses, and to assist with professional licensing.
Internet or Other Similar Network Activity
- Personal Information Collected: The Company may collect information about employees' use of the Internet or other similar network activity, including the following: browsing history, search history, log in/out and activity on the Company's electronic resources, and information regarding an employee's interaction with an Internet web site, application, or advertisement, and publicly available social media activity.
- Purposes of Use: to monitor use of the Company's information systems and other electronic resources or information systems, to conduct internal audits, to conduct internal investigations, to protect the safety and security of the Company’s facilities, and to impose discipline.
Sensory or Surveillance Data
- Personal Information Collected: The Company may collect sensory or surveillance data, including the following: recordings of customer service telephone calls and footage from video surveillance cameras.
- Purposes of Use: to protect the safety and security of the Company’s facilities and personnel through video surveillance, to monitor compliance with Company policies, to provide training, for quality assurance, and to determine whether to discipline employees.
Profile Data
- Personal Information Collected: The Company may collect profile data, including the following: results of self-assessment questionnaires for information concerning skills, engagement, initiative and preferences.
- Purposes of Use: Results used as a guide to assess employee initiative, engagement with the temporary job placement process, and as an insight for the employees to engage with recruiters for specific temporary job placement and preferences.
Background Screening Information
- Personal Information Collected: The Company may collect background screening information, including results of the following types of background screening: criminal history; sex offender registration; motor vehicle records; credit history; employment history; drug testing; and educational history.
- Purposes of Use: to screen employees for risks to the Company and continued suitability for their jobs and to evaluate employees for internal promotions.
Purposes Potentially Applicable To Any Of The Categories Of Personal Information Listed Above
The Company also may use employees’ Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:
- to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
- to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
- in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
- to manage licenses, permits and authorizations applicable to the Company’s business operations.
No Selling or Sharing of Personal Information
Company does NOT sell, as that term is defined under California law, or Share your Personal Information.
Retention Policy
Company retains each category of Personal Information that it collects about you for the applicable retention period listed in the Company’s U.S. Records Retention Policy. A copy of the policy is available upon request.