CANDIDATE 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”) describes 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 ’the Candidate’ or ’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) 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.

  • d) 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.

  • e) Technical Data means internet protocol (IP) addresses 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 our or others websites, apps and products and services, time zone settings of your device and your device location, the browser plug-in types and versions you use to access the Portal and our or others websites, apps and products and services, the operating system and platform type of the device you use, and other technology on the devices you use to access the Portal, our apps, websites, products and services, premises data including CCTV and door entry systems.

  • f) Phone Calls Data includes the number you spoke with us from, the time, date and duration of that contact.

  • g) Profile Data means your username and password, your interests, preferences, feedback and survey responses.

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

  • i) Sensitive Data,means, as applicable, 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.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some of the information listed above to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.

 

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 provide you with our services by finding you suitable jobs/assignments to apply for, helping you with training, or facilitating the process of applying for jobs/assignments. This includes sending your CV to prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, mail and/or other communication methods. a) Identity Data
b) Contact Data
c) Qualifications and Working Experience Data
d) Social Media Data
g) Profile Data 		Performance of a contract or taking steps prior to entering a contract Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To provide you with our services by assessing and selecting or rejecting your job application including, for example, setting up and conducting interviews. a) Identity Data
b) Contact Data
c) Qualifications and Working Experience Data
d) Social Media Data
g) Profile Data 		Performance of a contract or taking steps prior to entering a contract
 Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To provide you with our services by assessing the results thereto and as is otherwise needed in the recruitment processes including the final recruitment a) Identity Data
b) Contact Data
c) Qualifications and Working Experience Data
d) Social Media Data
g) Profile Data 		Performance of a contract or taking steps prior to entering a contract Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To make any adjustments that you may need in the workplace. a) Identity Data
i) Sensitive Data		 - - Performance of a contract or taking steps prior to entering a contract where we have agreed with you to provide adjustments in the workplace which are not covered by local laws;
- Compliance with legal obligations such as labour, discrimination and disability legal obligations		 Within 6 months of your last activity (last job application, interview, phone call or assessment) in the Portal.
To send you direct marketing, for example, via e-mail, messaging or telephone. a) Identity Data
b) Contact Data 		Consent For as long as you have opted in to receive our marketing.
To further develop, test and improve our website/Portal, or other existing or new systems/processes to better serve you. e) Technical Data
g) Profile Data 		Fulfilment of our legitimate interests to improve our systems Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To troubleshoot technical call problems on our networks. a) Identity Data
b) Contact Data
e) Technical Data
f) Phone Calls Data 		Fulfilment of our legitimate interests to deal with technical issues affecting our business Up to 6 months after fixing of the technical issue.
To perform studies and statistical and analytical research. For example, to compare the effectiveness of our placement of candidates between different business sectors and geographies and seek to identify factors that can influence any differences we identify. e) Technical Data
g) Profile Data
h) Marketing Communications Data 		Fulfilment of our legitimate interests to improve and develop our business Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To transfer data to third parties including Members of The Adecco Group, in accordance with section 7 below. Any category of data listed above, as necessary - Fulfilment of our legitimate interests to provide services and subcontract those services to third parties or in case of a business transaction
- Performance of the contract or taking steps prior to entering a contract
- Consent
- Compliance with government or law enforcement authorities 		Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal and 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. Up to 10 years from your last activity (last job application, interview, phone call or assessment) in the Portal and any additional period required under applicable local legal obligations.
To promote the security and protection of people, premises, systems and assets. a) Identity Data
e) Technical Data
i) Sensitive Data 		Fulfilment of our legitimate interests to ensure our business (and the people who work in it) are kept secure and safe Up to 1 month from your last visit to our premises.
To monitor compliance with internal policies and procedures. a) Identity Data
g) Profile Data 		Fulfilment of our legitimate interests to ensure that our policies and procedures are complied with Up to 1 year from your last activity.
To administer communications and other systems used by the Adecco Group (including internal contact databases). a) Identity Data
b) Contact Data
e) Technical Data
f) Phone Calls Data
h) Marketing Communications Data 		Fulfilment of our legitimate interests to ensure that our systems are functioning properly For as long as you have opted in to receive our marketing.
To investigate or respond to incidents and complaints. a) Identity Data
b) Contact Data
f) Phone Calls Data
i) Sensitive 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 		Up to 10 years from your incident or complaint or longer if there is legal action.
To promote internally the training sessions that have taken place and utilize their content, to market similar sessions internally and externally to third parties. a) Identity Data
b) Contact Data
h) Marketing Communications Data 		- Fulfilment of our legitimate interests (when it is internal) to train our candidates and develop our client offerings
- Consent (when it is to third parties) 		Up to 1 year from last activity.
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 Fulfilment of our legitimate interests to promote the growth and development of the Adecco Group Up to 1 year from last activity.


 

4. How do we collect your personal information?

The personal information we collect about you comes from the application forms or other materials you submit to us, your interactions with us and others as part of your application.

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 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?

You are not obliged to provide your personal information to us, but it would not be possible for us to work with you, or provide our services to you, if you do not provide us with a required minimum in order to assess your suitability for a position with us. It may also limit the Services that you can receive from us if you in some instances choose to provide us with limited personal information.

 

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 or applications, 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. While we do use AI systems, all decisions which may affect you are taken by our trained recruiters. Accordingly, these AI systems do not have legal effect.

For example, when our clients are looking for candidates for jobs, we can conduct a search of our lists of candidates 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 candidates that are most likely to fulfil the client’s requirement.

 

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

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


  • To our suppliers. We will, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you based on our legitimate interests. 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; the relevant 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) and back office finance and accounting management providers (who need to handle details of candidates in order to process accounts payable and receivable). We also engage suppliers who provide IT technology services and solutions, which might include video interview and skills assessment tools. 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”) within or outside the European Union. 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 for our legitimate interests; those IT functions are located among others in Czech Republic and France.
    • information is also shared with Members of The Adecco Group worldwide (including the legal entities acquired after the collection of information) for the purposes previously described or to propose offers to you adapted to your profile where you have consented to global data sharing within The Adecco Group to provide you with local or international opportunities in that market;
    • information is also shared with Members of The Adecco Group worldwide for administrative purposes based on our legitimate interests.

  • 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 or other business transaction, we may need to disclose your data to the prospective seller or buyer and their advisors based on our legitimate interests.

 

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, you have the right to access to some of your personal information (via the Portal) 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, 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 request that this information is updated or otherwise corrected. We would encourage you to access the self-service Portal where possible and update your personal information directly.
  • Right to be forgotten or to delete personal information.
    In certain circumstances you have the right to request that your personal information is deleted. You can 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 rights or obligations where we need 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. Please bear in mind, once your data is deleted, the Company might not be of service to you anymore. If you want to re-register with the Company again, you will need to re-enter your data.
  • 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. What about data security when using our systems?

You are responsible for keeping your login details to the Portal 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).

 

11. 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.

 

12. 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.