ASSOCIATES PRIVACY NOTICE

Latest update: 1st February 2024


Welcome to Adecco Luxembourg S.A.. (“Adecco”)! We look forward to working with you to help you to further develop your career.

This privacy notice (“Privacy Notice”) sets out what personal information we collect from you, how we collect, use and process it, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights. We know it is long, but please read this Privacy Notice carefully.

There is an index below so you can go straight to the relevant sections if you prefer.

INDEX

 

1. Some terms to be clear about

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

It may seem obvious, but in this Privacy Notice, you will be referred to as ’You’.

When we talk about ‘us’ or the ’Company’ we mean Adecco. We have our registered offices at 41 avenue de la Liberté L-1931 Luxembourg. The Company is part of the Adecco Group AG (Adecco Group) with company headquarters at Bellerivestrasse 30, 8008 Zurich, Switzerland, 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 search and apply for jobs the Company and its sister companies advertise which match your interests, skills and/or experience, in the locations where you have expressed an interest in working.

Finally, this Privacy Notice is about how we process your information as an individual. It is not about how we process information about companies (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' or 'data’ in this Privacy Notice.

 

2. What personal information does the Company collect and use?

We collect and use personal information to provide the best possible employment opportunities that are tailored to you, which we have grouped together as follows:

  • a) Identity Data : means your name, username, title, place of birth and documents evidencing your identity.

  • b) Contact Data means your billing address, delivery address, email addresses and telephone numbers.

  • c) Correspondence Data means records of written correspondence and phone calls with us including the email address, the number you contacted us from and the time, date and duration of that call or other contact.

  • d) Qualifications and Working Experience Data means your CV or resume, details of your education, training courses attended and internships, documents evidencing your right to work and any other information you listed on your resume or CV, photos and videos of your attendance at a video interview or training.

  • e) HR Data means your gender, nationality, proof of address and copies of documents evidencing your right to work in the locations you will work in, visas, work permits, records of your attendance, time spent on projects, training, promotions, investigations and disciplinary matters.

  • f) Payroll Data means your bank account information, national insurance or social security number, tax codes and reference numbers, your fees, salary and benefits information, details about your dependents and beneficiaries and any voluntary deductions you ask us to make from your salary and fees (like trade union membership or church dues if applicable).

  • g) Travel Data means travel data, credit card information, 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.

  • h) Photos and Videos Data means photos and videos from your attendance at training or similar sessions and/or from internal communications usage.

  • i) Social Media Data means your profile data on social media such as LinkedIn and other information you make public on or otherwise share with us from social media.

  • j) Marketing Communications Data means information about how you respond to email, sms, phone and other marketing campaigns.

  • k) Feedback Data means 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 and your feedback about us and our services through our satisfaction surveys or through any other way of communication, feedback and survey responses

  • l) Technical Data internet protocol (IP) address from which you access the Portal and our or others products and services, cookies (as set out in our Cookies Policy), your login data (such as the time, date and duration), the browser type and version you use to access the Portal and our or others websites, apps and products and services, weblogs, [traffic data], time zone settings of your device and its location, browser plug-in types and versions that you use, [other communication data], resources that you access on the Portal, our apps, websites, products and services, the operating system and platform type of the device you use, and details of other technology on the devices you use to access the Portal or our websites, apps, products or services, and also information about your use of our IT systems and premises, including CCTV and door entry systems.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some of the information listed above to enable us to manage our relationship with you.


In some cases, the personal information that we collect will also include ‘special categories of data’ (also known as or ‘sensitive information’), we call this Sensitive Data (m). This may include details of any disabilities and any accommodations we may need to make for you in the workplace as well as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data (such as sickness records, disability records, fitness for work and health insurance where it contains data relating to sickness), data about alleged or proven criminal offences, in each case where required or permitted by, and in compliance with, applicable law.

 

3. Why do we process your personal information and how long do we keep it for?

Purposes of the processing Type of data Legal basis to process your personal information Retention period
To manage and comply with your contract of employment or contract for services, and all other contracts and rules that govern our employment or other contractual relationship with you. a) Identity Data
b) Contact Data
c) Correspondence Data
d) Qualifications and Working Experience Data
e) HR Data
f) Payroll Data
i) Social Media Data
k) Feedback data
l) Technical data
m) Sensitive Data 		Performing a contract or taking steps prior to entering a contract in respect of the contract of employment or services with you
Compliance with legal obligations such as labour law		 Duration of your contract + any additional period required under applicable local legal obligations
To carry out other human resources activities (including the management of work, absence, training/people, travel, expenses and benefits including share schemes, and disciplinary procedures). a) Identity Data
b) Contact Data
c) Correspondence Data
d) Qualifications and Working Experience Data
e) HR Data
f) Payroll Data
g) Travel Data
i) Social Media Data
k) Feedback data
l) Technical data
m) Sensitive Data 		Performing a contract or taking steps prior to entering a contract in respect of the contract of employment or services with you
Compliance with legal obligations such as labour law		 Duration of your contract + any additional period required under applicable local legal obligations
To provide our associates with the assistance they expect, like finding them suitable assignments to work on, or facilitating the process of applying for new assignments. a) Identity Data
b) Contact Data
c) Correspondence Data
d) Qualifications and Working Experience Data
e) HR Data
i) Social Media Data
k) Feedback data
 Performance of a contract or taking steps prior to entering a contract Duration of your contract + any additional period required under applicable local legal obligations
To maintain and improve administration of talent (including for the purposes of workforce analysis and to request feedback from employees and associates). a) Identity Data
b) Contact Data
d) Qualifications and Working Experience Data
e) HR Data
k) Feedback data
Fulfilment of our legitimate interests to attract the right talent and to offer opportunities to new and existing employees and associates Duration of your contract + any additional period required under applicable local legal obligations
To further develop, test and improve our website/Portal, or other existing or new systems/processes to better serve you, our clients, other staff and third parties k) Feedback Data
l) Technical Data 		Fulfilment of our legitimate interests to improve and develop our business Duration of your contract + any additional period required under applicable local legal obligations
To transfer data to third parties in accordance with paragraph 6 below. Any category of data listed above as necessary Fulfilment of our legitimate interests to provide services and subcontract those services to third parties Duration of your contract + any additional period required under applicable local legal obligations
To comply with our legal obligations. Any category of data listed above as necessary Compliance with legal obligations such as keeping records for tax purposes or providing information to a public body or law enforcement agency. Duration of your contract + any additional period required under applicable local legal obligations
To promote the security and protection of people, premises, systems and assets. a) Identity Data
l) Technical Data
 Fulfilment of our legitimate interests to ensure our business (and the people who work in it) are kept secure and safe Duration of your contract + any additional period required under applicable local legal obligations
To monitor compliance with internal policies and procedures. a) Identity Data
c) Correspondence Data
e) HR Data
i) Social Media Data
k) Feedback Data
l) Technical Data 		Fulfilment of our legitimate interests to ensure that our policies and procedures are complied with Duration of your contract + any additional period required under applicable local legal obligations
To administer communications and other systems used by the Adecco Group (including internal contact databases). a) Identity Data
b) Contact Data
c) Correspondence Data
j) Marketing Communications Data
l) Technical Data 		Compliance with legal obligations such as labour law.
Fulfilment of our legitimate interests to resolve any incidents and complaints according to our internal procedures 		Duration of your contract + any additional period required under applicable local legal obligations
To report internally that training sessions have taken place and to keep a record of the content in order to use that content for other internal trainings or third parties (recorded trainings). a) Identity Data
h) Photos and Videos Data 		Consent Duration of your contract + any additional period required under applicable local legal obligations
To send internal communications, such as emails, announcements, news on the intranet. a) Identity Data
b) Contact Data
h) Photos and Videos Data 		Consent Duration of your contract + any additional period required under applicable local legal obligations
To 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. Any category of data listed above as necessary Compliance with legal obligations under any contract we have with a seller or purchaser.
Fulfilment of our legitimate interests to promote the growth and development of the Adecco Group 		Duration of your contract + any additional period required under applicable local legal obligations


 

4. How do we collect your personal information?

The personal information we collect about you comes from the application forms, any documents we ask you to complete during the onboarding process or other documents you submit to us and your interactions with us and others during the course of your employment with us.

In some cases, we will also collect personal information indirectly from third parties, such as from recruitment agencies that we work with, other entities in the Adecco Group if you transferred to us from that Adecco entity, background check providers and other administration services providers (for instance who provide our flexible benefits programme), other employees in any complaints or disciplinary reports submitted about you, or from publicly available sources such as LinkedIn and Twitter in accordance with applicable law.

 

5. Do you have to give us the personal information we ask for?

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 perform the contract we have entered into with you (such as paying you or providing a benefit), participate in certain processes such as feedback or career development (which may also not be in line with your contract with us) or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

 

6. Do we use artificial intelligence?

Yes, we do use artificial intelligence (AI) at times. However, we do not use your personal information in any automated decision making (a decision made solely by the creation and application of technologies without any human intervention) or profiling (processing of personal information with a range of technologies that reduce human intervention to evaluate certain conditions about an individual) that produces a legal effect or similarly significant effect concerning you.

We use a range of technologies to analyse your data. In all cases, there is always human intervention in these processes, as we use these tools to support our expert human decision makers.

We use automated systems/processes with the conditions described in the previous paragraph to help our staff manage large volumes of data, like job offerings and profiles, and we might use AI (for instance machine- learning, logic- or knowledge based and statistical approaches) to provide you, and our clients, with the services you request from us (e.g. finding the projects with the best fitting conditions on both sides). While we do use AI systems, all decisions which may affect you are taken by our trained staff members. Accordingly, these AI systems do not have legal effect.

For example, when we are looking for new opportunities or projects for you, we can conduct a search of our lists of job offerings using machine- learning, logic- or knowledge based and statistical approaches which uses attributes such as your job title, availability, skillset, assessment scores and locations, to compile a shortlist which displays a list of job offerings that are most likely to fulfil your requirements.

 

7. Do we transfer your personal information to third parties?

As mentioned at section 8 below, we usually disclose your personal information to third parties. This is done to complete the purposes set out at section 3 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). This category of third parties includes:
    • ✔ Salesforce.com EMEA Limited. This supplier is located in England. Hosting center in Frankfurt(Germany) and backup in Paris (France).
    • ✔ Impleo, for IT. This supplier is located in Luxembourg.
    • ✔ TCS, for IT. This supplier is located in India
    • ✔ Partenaires Sociaux. This supplier is based in Luxembourg.
    • ✔ IBGraf. This supplier is based in Luxembourg.

  • To members of The Adecco Group and their affiliates (“Members of The Adecco Group”) in other countries. A list of the countries in which we operate is available on our website at www.adeccogroup.com/worldwide-locations. 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 Group companies worldwide; those IT functions are located among others in France, Czech Republic and the Netherlands.
    • 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 worldwide (including the legal entities acquired after the collection of information) 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.

  • 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, based on the performance of our contract or prior to entering a contract. They owe contractual and other confidentiality obligations in relation to your data to us, and to you.

  • To government or law enforcement authorities. We will share your data with government, police, regulators or law enforcement authorities 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.

  • To prospective sellers or buyers and their advisors. 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 advisors.

 

8. Do we transfer your personal information outside your country?

Your personal information can be transferred and processed in one or more other countries, in- or outside the European Union or Switzerland. A full list of the countries in which we operate is available on our website at www.adeccogroup.com/worldwide-locations

We shall only transfer data to those parties set out in section 7 above who are outside the European Economic Area, UK or Switzerland:


You may request additional information in this respect and obtain a copy of the relevant safeguard by contacting us using the details set out below.

 

9. What are your rights regarding your personal information?

Under applicable data protection laws, you have the following rights:

  • Right to access and obtain a copy of your personal information.
    You are entitled to request confirmation of whether we process any of your personal information. Where this is the case, may have 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. In some limited circumstances, you also have the right to request that we transfer (“port”) your personal information direct to another third party provider.
  • Right to correct your personal information.
    If you can demonstrate that the personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
  • Right to be forgotten or to delete personal information.
    In certain circumstances you have the right to have your personal information deleted. You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
  • Right to restrict or object to the processing of your personal information. In certain circumstances, you have the right to obtain restriction of the processing of your personal information, or to object to certain processing thereof on grounds relating to your particular situation.
  • Right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you want to exercise any of your rights, please use our form by clicking here.

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 personal information has arisen.

 

10. Do we carry out any monitoring?

To the extent permitted by law, we reserve the right to audit, monitor and record the access, use and content of any data held or processed by our IT systems. We do this for the purposes related to the promotion of the security and protection of people, premises, systems and assets, and also to the administration of communications and other systems used by The Adecco Group. We have highlighted it in this Privacy Notice so that you are aware that your use of work related IT systems may be monitored by others.

 

11. What about data security when using our systems?

You are responsible for keeping your login details to our 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).

 

12. How do we handle changes to this Privacy Notice?

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

 

13. Contact

In case you:

  • have any questions or concerns regarding this Privacy Notice,
  • would like further information about how we protect your information (for example when we transfer it outside your country), or
  • want to contact The Adecco Group’s Data Protection Officer (DPO) or the local Privacy Lead, please email The Adecco Group’s DPO at globalprivacy@adeccogroup.com or the local Privacy Lead at privacy@adecco.lu


To exercise any of your rights related to your personal information, please fill in this form.