Privacy Policy - Manpower

This Privacy and Personal Data Protection Policy ("Policy") describes the framework applicable to personal data collected by ManpowerGroup in Romania, respectively by the following companies, each of which has the capacity of operator individually and separately:

Manpower Romania S.R.L., a limited liability company, registered at the Bucharest Trade Registry with registration number J40/4299/2003, unique registration code 15327494, having its registered office in Bucharest, Sector 6, Boulevard Iuliu Maniu no. 6Q, floor 10, area A, sector 6, Bucharest, Romania;

Manpower HR S.R.L., a limited liability company, registered at the Bucharest Trade Registry with registration number J40/5258/2014, unique registration code 33121785, with its registered office in Iuliu Maniu Boulevard no. 6Q, floor 10, area A rooms number 1 and 2, sector 6, Bucharest, Romania.
(each individually referred to as "Operator", and individually and/or collectively as "Manpower"), as required by law, including the provisions of the General Data Protection Regulation ("GDPR").

Personal data operator

The operator of personal data is each of the following companies:

Manpower Romania S.R.L., a limited liability company, registered at the Bucharest Trade Registry with registration number J40/4299/2003, unique registration code 15327494, having its registered office in Bucharest, Sector 6, Boulevard Iuliu Maniu no. 6Q, floor 10, area A, sector 6, Bucharest, Romania;

Manpower HR S.R.L, a limited liability company, registered at the Bucharest Trade Registry with registration number J40/5258/2014, unique registration code 33121785, with its registered office in Iuliu Maniu Boulevard no. 6Q, floor 10, area A rooms number 1 and 2, sector 6, Bucharest, Romania.
The personal data collected will be controlled and processed by Manpower. Personal data may also be processed or jointly controlled by Manpower affiliates.

This Policy applies to: (1) our candidates and beneficiaries of our career counseling and guidance services, (2) our employees / our temporary employees, or natural persons to whom we provide professional reintegration or career transition services, (3) to users of the websites and applications listed here (the “Sites”) and (4) representatives of our business partners, customers and suppliers.

This Policy describes the categories of personal data or personal information that we collect, how we use the information, the manner and purposes in which we process and protect the data we collect, the duration of storage, the situations in which we transfer the data and the recipients, such as and the rights and choices individuals have regarding the use of personal data. We also describe how you can contact us about our privacy and data protection policies and how you can exercise your rights. Our privacy and data protection policies may contain variations depending on the jurisdictions in which we operate to reflect local practices and legal requirements, and you can consult the specific local provisions by visiting the local websites.
Click on one of the links below to access the listed section:

Privacy and Data Protection Policy

The personal data we collect
How we use the personal data we collect
Legitimate interest
How we process and protect personal data
Duration of processing the personal data we collect
Persons to whom we may transfer your personal information and data
Data transfers
Your rights and options
Updating our Policy
How to contact us

I. The personal data we collect

We collect personal data about you in various ways, such as when you access and visit our Sites, including when you create and update the account you register using the Sites, and from different channels of social media; at our events; by phone and fax; through applications for various jobs; in relation to different types of recruitment processes; or in connection with our service providers or business partners. We may collect various types of personal data depending on the nature of the relationship, including but not limited to (subject to applicable law):

identification or contact data (such as name, surname, home address, professional address, e-mail address, telephone number, job title);
your username and password when you register on our sites;
the information you provide about other persons whom you wish us to contact (the Operator assumes that such person has previously given authorization for such communication);
other information you may provide to us, such as in surveys or through the "Contact Us" feature on our Sites.

In addition, if you are a candidate, an employee / temporary employee, submit your resume for a job or create an account to submit your resume for a job, we may collect the following types of personal data (according to local legislation):

data on education and professional experience;
known foreign languages and other professional skills;
personal numerical code or other personal data having an identification function;
date of birth;
sex;
bank account information;
citizenship and work permits;
information on benefits;
information on fees and taxes;
references about you; and
oany other data contained in your CV that you provide regarding your career areas of interest and other data about your qualifications for employment;

and when required by law, based on your express consent:

information about your disability and health;
medical history, data on criminal convictions and other checks on your person.

In addition, we may collect information that you provide to us about other individuals, such as information about who we may contact in an emergency. If you visit us at our headquarters or our local offices, or if you write or call us about various requests or matters of interest to you, we may collect your name and contact details, as well as other personal data that you provide them directly to us. The Employee and the Temporary Employee (hereinafter referred to individually as the "Employee" and collectively as the "Employees"), as applicable, understand and acknowledge that Manpower, as an employer, collects, processes and stores personal data of the employee / temporary employee and his dependents in order to conclude and execute his employment contract with Manpower.

II. How we use the personal data

The Operator collects and uses the collected data for the following purposes (as permitted by applicable law):

providing solutions for the labor force and placing people on the labor market;
creating and managing online accounts;
processing payments;
managing relationships with our customers and suppliers;
to the extent permitted by applicable law and in accordance with the Cookies and Marketing Actions Policy (which are available on our website), sending promotional materials, vacancy alerts and other communications;
to the extent permitted by applicable law, communicating and managing participation in special events, promotions, programs, offers, surveys, contests and market studies;
providing answers to people's questions and requests;
managing, evaluating and improving our business (including developing, analyzing and improving our services; managing communications; performing data analysis and performing accounting, auditing and other internal activities);
protecting against fraud, identifying and tracking the prevention of fraud and other illegal activities, claims for compensation and other claims for damage coverage; and
complying with and enforcing applicable legal requirements, applicable industry standards, contractual obligations and our policies.

All processing will be carried out on the basis of appropriate legal grounds which could fall into several categories, including:

consent or express consent of the data subject, if this is required by applicable law;
to ensure that we comply with a legal or contractual requirement or a requirement necessary to enter into / amend / terminate a contract (for example, processing your personal data to ensure that your wages and taxes are paid).
the legitimate interest of the Operator (for example, to allow the user to benefit from the services we offer).

In addition to the activities listed above, if you are an individual applying for a position or creating an account to apply for a position, to the extent permitted by applicable law, we use the information described in this Policy to: purposes:

offering employment and work opportunities;
providing human resources services to you, including benefits programs, payroll, performance management and disciplinary actions;
providing additional services such as training programs, career counseling and professional reintegration services;
assessment of your skills and qualifications for different jobs; and
performing data analysis, such as (i) evaluating candidates; (ii) assessment of individual performance and competences, including assessment of skills required for different activities; (iii) identification of skills deficit; (iv) using data to connect candidates with different employers and (v) analyzing categories of data related to the labor market (eg trends in employment practices).

We may also use the data for other purposes, in which case we will provide you with specific information at or before the time of collection.
If you are an Employee, Manpower processes your personal data and that of your dependents, if applicable, for the following purposes:

In order to conclude and execute the employment contract / temporary employment contract to which the Employee is a party, as well as to modify or terminate the Employee's employment contract.
In order to pay the salary to the Employee, as well as other increments, compensations, bonuses, meal vouchers, other benefits, etc. from which the Employee could benefit.
In order to fulfill Manpower's obligations in the field of employment and social security and social protection, as well as in order to fulfill Manpower's obligations in health and safety at work, emergency situations, occupational medicine, including regarding the evaluation of the Employee's work capacity.
In order to provide training sessions, including e-learning / online.
In order to keep track of all employees in the REVISAL register, including the Employee, according to the employer's labor law obligations.
In order to submit statements, requests, documents to the competent authorities, including the ANAF, the Labor Inspectorate, the General Inspectorate for Immigration, the General Inspectorate for Emergency Situations, the Pension House, the Health Insurance House, in order to comply with the legal obligations of the employer.
In order to issue certificates at the request of the Employee.
In order to recover any claims owed by the Employee to the employer or to recover any claims owed by the Employee to third parties (within the garnishment procedure).
In order to prepare certain reports to companies in the Manpower Group, for administrative purposes.
In order to monitor the location of the equipment used by the Employee in the performance of his duties.
In order to monitor the location of the equipment used by the Employee in the performance of his duties.
For the purpose of accessing location data via remote internet connection to ensure the security of the company's IT system.

III. Legitimate interest

The Operator may process personal data for certain legitimate purposes in carrying out its activity, which include some of the following:

where the process enables us to improve, modify, personalize or otherwise improve our services/communications for the benefit of our customers, candidates and Employees;
to identify and prevent fraud;
to enhance the security of our network and IT systems;
to better understand how people interact with our sites;
for direct marketing purposes;
to provide you with communications by mail, which we consider to be of interest to you;
to determine the effectiveness of promotional campaigns and advertising.

Whenever we process data for these purposes, we will ensure that we pay particular attention to your rights. You have the right to object to such processing and, if you wish to do so, please write to us at DataPrivacy@manpower.ro.

IV. How we process and protect personal data

We process the personal data we collect by automated means, for the purposes defined above and for a certain period of time, which complies with our internal retention policy, to ensure that the personal data is not kept longer than required. We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. To ensure the appropriate security and confidentiality of personal data, we apply the following security measures:

Data encryption;
Adequate user authentication measures;
Secure network infrastructure;
Network monitoring solutions.

V. The duration of the processing of the personal data we collect

We store in our systems the personal data that we collect in a way that allows the identification of data subjects limited to the time period for which it is necessary in light of the purposes for which the data were collected or for which this data is subsequently processed. We determine this specific time period by considering:

The need to keep personal data stored in order to provide our services;
To protect the legitimate interests of the Operator, in accordance with this Policy;
The existence of specific legal obligations that make necessary the related processing and storage for a certain period of time;
In relation to Employees, personal data will be stored and retained by Manpower as follows:
Personal Data necessary to achieve the purposes mentioned in point II, 10), until the date of withdrawal of consent for data processing by the Employee;
Personal Data necessary to achieve the purposes mentioned in points II 9), 11), 12) above, until the employer's legitimate interest ceases or until the Employee exercises the right to object;
Personal Data necessary to achieve the purposes mentioned in points II 3), 4), 6), 7), until the termination of the employment contract with the Employee;
The Personal Data necessary to achieve the purposes mentioned in point II 1) above, are kept within the personnel files, for a period of 75 years from the preparation of the personnel file, according to the National Archives Law no. 16/1996;
The Personal Data necessary to achieve the purpose mentioned in point II 5) above, are kept for a period of 75 years, according to the National Archives Law no. 16/1996;
The Personal Data that can be found in any supporting documents that are the basis of the entries in the accounting records are kept in the Employer's archive for 10 years, according to the provisions of the Accounting Law no. 82/1991;
The Personal Data that can be found in the Employer's salary statements (according to point II 2) above), are kept for 50 years, according to the provisions of the Accounting Law no. 82/1991.
After the expiration of the above terms, personal data is deleted and/or destroyed from Manpower's records/databases.

VI. Persons to whom we may transfer your personal information and data

We do not disclose the personal data we collect about you, except as described in this Policy or in separate notices provided in connection with certain activities. We may share personal data with providers who provide services on our behalf based on our instructions. We do not authorize these providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. We may also share your personal data with (i) our subsidiaries and affiliates; (ii) if you are a job candidate, to clients who may have employment opportunities or interest in candidate placement; and (iii) other people we work with, such as employment consultants and subcontractors to find you a job.
In addition, we may disclose personal data about you (i) if we are required to do so by law; (ii) to law enforcement authorities or other officials based on a lawful disclosure request; and (iii) 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. We also reserve the right to transfer the personal data we have about you if we sell or transfer all or part of our business or assets (including in the event of reorganization, dissolution or liquidation).
Regarding our Employees, within the processing operations carried out for the purposes mentioned in points II 1)-12) above, the Personal Data of the Employee will be transferred to the following third parties, as follows:
(a) the service providers used by Manpower, including: the provider of occupational medicine and medical subscription services; the supplier of meal vouchers and gift vouchers; voluntary pension insurance service providers; banks, in order to pay the salary by bank transfer; the external archiving service provider used by Manpower; the courier service provider with which Manpower collaborates, only when there are documents to be sent involving the Employee and only minimal Personal Data necessary for the delivery services (name, surname, telephone, address);
(b) providers of training services and other similar services;
(c) external consultants;
((d) other Manpower group companies, within Manpower's reporting/administrative activities.
(e) authorities, including: (i) the National Tax Administration Agency, for the submission of various declarations according to the applicable legal provisions; (ii) The Territorial Labor Inspectorate and the General Inspectorate for Emergency Situations, to fulfill the obligations of keeping records of employees, as well as to fulfill the legal requirements of health and safety at work and the prevention and extinguishing of fires / emergency situations; (iii) the Health Insurance House and the Pension House, for the submission of various applications and forms; (iv) The General Inspectorate for Immigration, in order to fulfill the obligations of keeping records of employees for foreign citizens, (v) as well as other authorities for the fulfillment of other legal obligations.
All the data transfers mentioned above are carried out with Manpower respecting the principles related to the processing of personal data, in particular the principle of personal data minimization – Manpower transmits to third parties only the personal data that is strictly necessary to achieve the stated purposes.

VII. Data transfers

We may also transfer the personal data we collect about you outside the country where the information was originally collected. Those countries may not have the same data protection laws as the country where you originally provided your personal data. When we transfer your personal data to other countries, we will protect that data as described in this Policy and such transfers will be in accordance with applicable law.
The countries to which we may transfer your personal data that we collect may be:

Within the European Union;
Outside the European Union.

When we transfer personal data from within the European Union to countries or international organizations that are outside the European Union, the transfer takes place on the basis of:

The decision of the European Commission regarding the degree of adequacy;
in the absence of a decision regarding the degree of adequacy, based on other legal grounds allowed: (i) a legally binding and enforceable instrument between public authorities or entities; (ii) mandatory corporate rules; (iii) standard data protection clauses (previously called standard clauses) adopted by the Commission, etc.

VIII. Your rights and options

En applicable law so requires, a data subject may exercise, pursuant to Articles 15-22 of the GDPR, the following specific rights:

The right to information: the right of the data subject to receive information regarding the processing of Personal Data. Compliance with this right by Manpower is achieved through this information.
The right of access: The data subject has the right to obtain from the company a confirmation that personal data concerning him or her is being processed or not and, if so, access to the respective data and the provision of information on data processing
The right to rectification: The data subject has the right to obtain from the operator, the rectification of any inaccurate or incomplete personal data concerning him, in order to ensure the accuracy of such information and to ensure adequate processing.
The right to deletion: The data subject has the right to obtain from the operator the deletion of personal data concerning him, and the operator has the obligation to delete the personal data.
The right to restrict processing: The data subject has the right to request the Operator to limit the processing of his data.
The right to data portability: The data subject has the right to request data portability, which means that the data subject can receive the personal data originally provided in a structured and commonly used format, or that the data subject can request the transfer of the data to another Operator.
The right to object: The data subject who provides an Operator with personal data has the right to object at any time to the processing of the data for several reasons provided for in the GDPR, without having to justify his decision.
The right not to be the subject of an automated individual decision: The data subject has the right not to be the subject of a decision based exclusively on automated processing, including the creation of profiles, if this creation produces a legal effect on the data subject or significantly affects him/her similar.
The right to lodge a complaint with a supervisory authority: Every data subject has the right to lodge a complaint with a supervisory authority, in particular in the EU Member State where they have their habitual residence, place of work or place of it is assumed that the violation has been carried out, if the data subject considers that the processing of personal data concerning him violates the provisions of the GDPR.

Whenever the processing is based on consent, according to art. 7 of the GDPR, the data subject can withdraw his consent at any time.
If you require more information about the processing of your personal data, please see the "How to contact us" section below.

IX. Updating our Policy

This Policy (including any annexes) may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our Sites, indicating at the top of each notice when the last update was made.

X. How you can contact us

If you have any questions or comments about this Policy, or if you wish to exercise your rights, please write to:
For Manpower Romania S.R.L.: by e-mail to the following e-mail address: DataPrivacy@manpower.ro or you can send a written request by post to the following address: Bulevardul Iuliu Maniu no. 6Q, floor 10, area A, sector 6, Bucharest, Romania;
For Manpower HR S.R.L: by e-mail to the following e-mail address: DataPrivacy@manpower.ro or you can send a written request by post to the following address: Bulevardul Iuliu Maniu no. 6Q, floor 10, area A rooms number 1 and 2, sector 6, Bucharest, Romania.

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Privacy policy and protection of personal data