General Privacy Policy
GDPR Privacy Policy
ManpowerGroup's overriding goal is to ensure the confidentiality, security of the personal data of our Customers, Employees, Job Candidates and Website Users as well as transparency and lawfulness in connection with the processing of such data.
The Privacy Policy describes how personal data is protected and processed in accordance with the standards set forth in applicable laws.
PERSONAL DATA CONTROLLER – STATEMENT OF JOINT CONTROLLERSHIP
Pursuant to
Article 13(1) and (2) and Article 14(1) and (2) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ EU L 119, 4.5.2016 (hereinafter referred to as “GDPR”), we would like to inform you that the Joint Controllers of your personal data are the companies of ManpowerGroup (hereinafter referred to as “WADO”):
ManpowerGroup Sp. z o.o. – KRS No. 0000062137, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Transactions Sp. z o.o. – KRS No. 0000339387, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Services Sp. z o.o. – KRS No. 0000228311, registered seat at: 00-105 Warsaw, ul. Prosta 68
MP Actions Sp. z o.o. – KRS No. 0000234796, registered seat at: 00-838 Warsaw, ul. Prosta 68
ManpowerGroup Solutions Sp. z o.o. – KRS No. 0000373518, registered seat at: 00-838 Warsaw, ul. Prosta 68
MP Management Sp. z o.o. – KRS No. 0000482136, registered seat at: 90-033 Łódź, ul. Kopcińskiego 79
WAYS OF OBTAINING DATA
Directly from Data Subjects as part of ongoing recruitment processes, most often through the Candidate's expression of a desire to participate in the recruitment process via recruitment forms, candidate accounts, job fair surveys, and by telephone;
Directly from Data Subjects – obtained when Data Subjects use the website;
Directly from Data Subjects at the time of hiring an employee (employment forms, employment contracts, civil law contracts, B2B, medical referrals);
Directly from Data Subjects at the time of joining Benefit programs and internal training;
Indirectly, as part of the sharing of data by other controllers under the law, or as a processor entrusted with the processing of data for the purposes specified by another controller;
Indirectly, through mutual data sharing between business partners, customers and service providers, including contact data of representatives and employees of contracting parties.
Indirectly, as part of the sharing of personal data by third parties and business partners.
AREAS OF JOINT CONTROLLERSHIP
Within the operations of the ManpowerGroup and all of its subsidiaries, we distinguish the following areas of joint controllership:
– RECRUITMENT – an area of internal and external recruitment conducted jointly on behalf of all companies using a common database of job candidates,
– HR AND PAYROLL SERVICE – of internal, external and temporary employees, which is carried out by the HR and Payroll Department shared by all companies,
– PAYROLL – payroll services for external and temporary employees, which is carried out by the Payroll Department shared by all companies,
– ACCOUNTING – conducted for all companies by a common Accounting Department,
– MARKETING AND PUBLIC RELATIONS – carried out by persons employed by WADO jointly for all companies,
– LEGAL SERVICE AND ADVICE – the area of cooperation with customers, keeping a record of commercial contracts by one Legal Department and contracts with customers.
ESSENTIAL CATEGORIES OF PERSONAL DATA SUBJECTS THAT WE PROCESS
– job candidates;
– temporary employees hired under the provisions of the Act on the Employment of Temporary Employees;
– external employees performing work or services at the Customer's premises;
– WADO internal employees;
– users of this website;
– employees or associates of our Customers or Suppliers.
PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
Users' personal data may be processed:
(a) for the purpose of contact, i.e. to answer the questions asked by the User via the contact form and to obtain information about the Joint Controllers' offer – in this case, the processing of data by the Joint Controllers takes place based on the User's consent (Article 6(1)(a) GDPR);
(b) for the purposes of the Joint Controllers' legitimate interests related to the operation of the website, including analysing the User's use of the website (Article 6(1)(f) GDPR);
(c) in order to pursue the legitimate interests of the Joint Controllers, which may include, but are not limited to, establishing, asserting and defending claims, preventing crimes and conducting related investigations, ensuring accountability in accordance with the GDPR, managing and further developing business operations, including risk management (Article 6(1)(f) GDPR);
(d) for the purposes of direct marketing of the Joint Controllers, including the selection of services to meet the needs of Users (including profiling) based on cookies and other similar technologies, as referred to in point 9 – in this case, the processing of data by the Joint Controllers takes place based on the legitimate interest of the Joint Controllers (Article 6(1)(f) GDPR);
(e) for marketing purposes of the Joint Controllers, carried out in particular through the newsletter service, resulting from the consent given by the User (Article 6(1)(a) GDPR);
(f) in order to conduct the recruitment process based on the consent of job candidates and employees to the processing of personal data – Article 6(1)(a) GDPR, Article 9(2)(a) GDPR;
(g) for the purpose of entering into a contract, performance of the contract and execution of the contract – Article 6(1)(b) GDPR;
(h) for the purpose of fulfilling the legal obligations of the employing entity, arising in particular from the provisions of labour law and the obligations of the temporary employment agency under the provisions of the Act on the Employment of Temporary Employees – Article 6(1)(c) GDPR.
RIGHTS OF DATA SUBJECTS
We would like to inform you that all Data Subjects whose data we obtain directly have the right (depending on the legal basis of the processing) to withdraw their consent to the processing of personal data, the right to demand from WADO access to their personal data, rectification, erasure or restriction of processing, as well as the right to object to the processing and, in the case of Data Subjects whose data we obtained directly from Data Subjects, also the right to data portability.
Please be advised that you can withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out beforehand. For evidence purposes, please withdraw your consents in writing by sending a letter to the registered seat address or via e-mail.
Exercise of the above-mentioned rights is possible through the form available on the Application Support Portal (click). For those who do not use the Internet, WADO provide the option of making a request by e-mail: ul. Prosta 68, 00-838, Warsaw or by submitting the request in person at the head office or any WADO branch.
Data Subjects also have the right to lodge a complaint with the supervisory authority (UODO [Office for Personal Data Protection], ul. Stawki 2, 00-193 Warsaw).
We also inform that:
– automated decisions (decisions without significant human involvement) will not be made with respect to Data Subjects, and, generally, personal data of Data Subjects will not be subject to profiling by WADO.
– in case the processing of personal data violates applicable laws, all Data Subjects have the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection.
TRANSFER OF DATA TO THIRD COUNTRIES
As a general rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the countries of the European Union and Iceland, Norway and Liechtenstein. Your personal data may be transferred to the United Kingdom of Great Britain and Northern Ireland, against which, on 28 June 2021 the European Commission issued a decision finding an adequate level of protection for personal data.
In some cases, particularly in connection with the implementation of cooperation with IT solution providers or the need to transfer data to a potential employer, your personal data may be transferred to other third countries. In this case, the personal data safeguards referred to in Articles 46–49 GDPR, such as standard data protection clauses adopted by the European Commission, will be applied.
RECIPIENTS OF PERSONAL DATA
We may transfer personal data, depending on the purpose and legal basis, in part or in whole to other entities. Recipients of personal data are most often:
- WADO's customers, including primarily job seekers;
– service providers – entities that process data on our behalf and according to our instructions and for a purpose that is strictly defined by us;
– infrastructure, IT, technical and maintenance service providers;
– benefit providers;
– public institutions – to which data is transferred on the basis of the law;
– audit firms, tax consultants, law firms and others.
RETENTION PERIOD FOR PERSONAL DATA
The Joint Controllers process the User's personal data in the manner and for the period of time that is necessary to fulfil the purposes for which the data was collected.
In the case of data processing:
(a) based on the User's consent – the User's data will be processed until the consent is withdrawn;
(b) in order to ensure compliance with legal obligations imposed on the Joint Controllers – the User's data will be processed for the period required by law;
(c) for the purposes of direct marketing of the Joint Controllers, including selection of services to meet the needs of the User (profiling) – the User's data will be processed until the User raises an objection or withdraws consent;
(d) for the purpose of concluding, performing, executing a contract – until the termination of cooperation and the expiration of limitation periods;
(e) for the purposes of realisation of other legitimate interests of the Joint Controllers – data will be processed until the realisation of the WADO's legitimate interests or consideration of an objection raised by the User or the expiration of the period of limitation of claims.
In the case of recruitment processes, the retention period of personal data in our organisation has been set for a period of 1 month from the date of completion of the ongoing recruitment, and in the case of consent to process data for future recruitments – for a period of up to 3 years from the submission of the application or until the withdrawal of consent to processing, whichever occurs first.
Once the recruitment process has been completed, the data may be kept for the period necessary for the purposes of establishing, asserting and defending claims, which constitutes a legitimate interest of WADO within the meaning of Article 6(1)(f) GDPR.
For personal data processed under the law, WADO shall apply a retention period in accordance with applicable laws.
In the case of data processed for WADO's legitimate interest outside the contractual relationship, we process the data for as long as we have a legitimate interest.
DATA PROTECTION OFFICER
We take the protection of personal data very seriously, which is why in the course of our activities as WADO (by an appropriate resolution as each company) we have appointed a single, joint Data Protection Officer, who can be contacted by e-mail: [email protected], by mail: ul. Prosta 68, 00-838, Warsaw and through the form available on the Application Service Portal (click).
Website Privacy Policy
VERSION DATED 01.03.2026
ManpowerGroup's primary goal is to ensure the confidentiality and security of the personal data of our Clients, Employees, Job Candidates, and Users of the Manpower.pl and Experis.pl websites, as well as transparency and compliance with the law in relation to their processing.
The Privacy Policy of the Website/Experis Website describes how personal data is protected and processed in accordance with the standards set out in applicable law.
I. PERSONAL DATA CONTROLLER
The controller of your personal data processed for the purposes specified in the Terms and Conditions of Electronic Services of ManpowerGroup Websites is the Service Provider, i.e. the companies comprising the ManpowerGroup Capital Group, namely ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., MP Services Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o. with its registered office at ul. Prosta 68 in Warsaw, and MP Management Sp. z o.o. with its registered office at ul. Kopcińskiego 79, 90-033 Łódź (hereinafter: Joint Controllers or JCC).
II. METHODS OF DATA COLLECTION
Your data will be collected:
• directly from you in connection with your visit to the Website/Experis Website or in connection with your use of one or more services or functionalities described in the Terms and Conditions of Electronic Services of ManpowerGroup Websites (hereinafter: Terms and Conditions)
III. CATEGORIES OF PERSONAL DATA SUBJECTS WE PROCESS
In connection with the provision of our Services, we process the data of:
• job candidates;
• Users of the Website/Experis Website.
IV. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We process your data:
• for the purpose of responding to you, i.e. to answer your questions and obtain feedback – in this case, the processing of personal data is based on the legitimate interest of the Joint Controllers, which consists in the need to use your personal data for the purpose of preparing answers to your questions (Article 6(1)(f) of the GDPR);
• for purposes related to the conclusion and performance of a contract for the provision of ManpowerGroup's online services, in accordance with the rules set out in the Terms and Conditions (Article 6(1)(b) of the GDPR), and as part of these processes we may take the following actions, among others:
- identification and/or verification of identity;
- sending updates and notifications regarding the services received and other related communications;
• for the purpose of possible (only if necessary) investigation and defense against claims – the processing of personal data is based on the legitimate interest of the controller, consisting in the need to defend its rights (Article 6(1)(f) and Article 9(2)(f) of the GDPR);
• for the purpose of conducting statistical and analytical activities related to the functioning of ManpowerGroup websites – in this case, personal data is processed on the basis of the legitimate interest of the controller, consisting in the need to develop and evaluate the services provided (Article . 6(1)(f) of the GDPR), and as part of these processes we may undertake, among other things, the following activities:
- analysis of the use of ManpowerGroup websites,
- analysis of our candidate database,
- assessment of individual performance and skills, including assessment of job-related skills,
- identifying skills shortages,
- matching individuals and potential employment opportunities,
- analysis of pipeline data (trends in recruitment practices),
- determining the effectiveness of our engagement strategy,
- determining the effectiveness of our products and services, and
developing and training artificial intelligence (AI) models, including machine learning
• for the purpose of sending commercial information, including marketing communications, regarding products and services offered by companies in the ManpowerGroup Capital Group - pursuant to Article 6(1)(a) of the GDPR;
• for the purposes of direct marketing by the Joint Controllers, including the selection of services tailored to the needs of Users (including profiling) based on cookies and other similar technologies referred to in the Cookie Policy – in this case, data processing by the Joint Controllers is based on the legitimate interest of the Joint Controllers (Article 6(1)(f) of the GDPR) or consent given (Article 6(1)(a) of the GDPR);
- for purposes related to the conclusion and performance of an employment contract or other civil law contract in connection with recruitment, including for the purpose of verifying residence and employment documents and legalizing employment (Article 6(1)(b) and Article 9(b) of the GDPR);
• for the purpose of fulfilling any legal obligations of the employer, resulting, inter alia, from labor law provisions and the obligations of a temporary employment agency resulting from the provisions of the Act on the Employment of Temporary Workers, and for purposes related to the performance of such contracts – Article 6(1)(c) and Article 9(b) of the GDPR;
• to take action at the request of an authorized entity prior to the conclusion of a contract – in the case of seeking to commence cooperation and then cooperation on the basis of a civil law contract (Article 6(1)(b) of the GDPR).
• for the purposes of the legitimate interests pursued by the Joint Controllers, which may include, among others, ensuring compliance and accountability in accordance with the GDPR (Article 6(1)(f) of the GDPR), and in particular:
- conducting audits of our processes and documentation;
- protecting against fraud, identifying and seeking to prevent fraud, misleading practices, and other illegal activities, claims, and other liabilities;
- enhancing the security of our networks and information systems;
- complying with and enforcing applicable legal requirements, exercising or defending legal claims, relevant industry standards, contractual obligations, and our policies;
• to provide recruitment services, including informing about ongoing recruitment processes, verifying qualifications, experience, employment opportunities, and recommending candidates to clients (Article 6(1)(a), (b), or (f) of the GDPR), as well as:
- coaching, providing feedback, analysis, advice, and guidance to support you in managing and developing your career;
- tailoring and personalizing the support we offer based on qualifications and other criteria;
• to conduct the recruitment process in connection with the voluntary provision of special categori
• to conduct the recruitment process in connection with the voluntary provision of special categories of data in accordance with Article 9(2)(a) of the GDPR.
- to provide candidates with information about the starting salary or salary ranges for a given position, applicable remuneration regulations/collective agreement provisions (if applicable), as well as promotion rules and salary progression criteria (Article 6( 1(c) of the GDPR, in connection with the provisions of Directive (EU) 2023/970 of the European Parliament and of the Council and the provisions of the Act of June 26, 1974, Labor Code),
We may also use this information for other purposes, for which you will receive a separate information clause or a supplement to this clause.
WADO's legitimate interest
Depending on applicable regulations, WADO has the right to process personal data for specific legitimate interests, which may include some or all of the following:
- improving, modifying, personalizing, or otherwise enhancing our services/communications for the benefit of our customers, candidates, and associates, for example, through the use of technical measures such as call transcription features;
- identifying and preventing fraud;
- enhancing the security of our networks and information systems;
- increasing our understanding of how visitors and users use our websites and applications;
- determining the effectiveness of promotional campaigns and advertisements;
- using AI support, as described in the Terms and Conditions.
Whenever we process data for these purposes, we take care to protect your rights. You can object to such processing, and you can do so by contacting us as indicated below in the "How to contact us" section. Please note that if you exercise your right to object, this may affect our ability to provide and deliver services to you.
V. RIGHTS OF DATA SUBJECTS
You have the following rights:
• the right to withdraw your consent to the processing of your personal data;
the right to access your personal data;
• the right to request the rectification of your personal data;
• the right to request the deletion of your personal data;
• the right to request restriction of the processing of your personal data;
• the right to object to the processing of your personal data;
• the right to request the transfer of your personal data;
The above rights can be exercised using the form available on the Request Service Portal website. For those who do not use the Internet, the Joint Controllers provide the option of submitting a request by post: ul. Prosta 68, 00-838, Warsaw, or by delivering the request in person to the headquarters or any branch of the Joint Controllers.
After you submit your request, we may contact you directly or through our secure Request Service Portal to verify your email address and then your identity before we disclose, modify, or delete your data. We are only required to respond to verifiable and reasonable requests. If we cannot verify your identity, we may ask you for additional verification information. We will not use this information for anything other than verification. If the content of your request is unclear, we may also ask you for additional information regarding the content and scope of the request.
If we are unable to verify your identity or determine the content of your request with sufficient certainty to respond to your request, we will promptly notify you and explain why we cannot verify your identity or process your request.
Privacy requests submitted by an agent
You may appoint an authorized representative to exercise your rights on your behalf. If an authorized representative submits a request on your behalf, they must also provide a document signed by you authorizing them to submit the request on your behalf. In addition, we may ask both you and your representative to follow the identity verification procedure described above.
Processing of data relating to minors
We respect the privacy of children. Our websites and services are generally not intended for or directed at children. If you are a parent or guardian, please contact us if you believe we may have collected information from your child, and we will investigate and take appropriate action.
In addition to the rights described above, you also have the right to lodge a complaint with the President of the Personal Data Protection Office.
VI. RECIPIENTS OF PERSONAL DATA
In order to ensure the proper provision of services, your personal data may be transferred to:
• our Clients – entities seeking job candidates who post job offers on our website;
• our Suppliers – entities providing us with infrastructure, IT, technical, maintenance, administrative, legal, tax, auditing, and other services.
- affiliated entities;
• third parties from whom cookies or other technologies referred to in the Cookie Policy originate.
Below we provide more detailed information in this regard.
We may disclose some of your personal data to suppliers who provide services on our behalf, in accordance with our instructions, in order to provide you with our Websites and services. These suppliers may include, among others, IT and cloud service providers. We strive to ensure that this data is limited to the level necessary to perform specific tasks. We do not authorize providers who process data on our behalf to use or disclose this information unless it is necessary to perform services or comply with legal requirements. Personal data will not be sold, rented, distributed, or shared with providers for their own commercial purposes, including for their direct marketing purposes.
We may also disclose your personal data in particular: (i) to our subsidiaries and affiliates; (ii) if you are a job candidate, to clients who may have job openings or an interest in hiring our candidates; and (iii) with other parties we work with, such as consultants providing career support services or employment providers who work with us on recruitment and hiring (iv) if you use talent management services, we may disclose the status or progress of your program to the client—a potential employer— along with any relevant results of the recruitment process.
In addition, we may disclose personal information about you (i) if required by law or legal process; (ii) to law enforcement or other government officials pursuant to 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 fraud or illegal activity. We also reserve the right to transfer the personal information we hold about you in the event of a sale or transfer of all or part of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
Links to external tools and resources
We may provide links to external websites operated by organizations not affiliated with WADO. We do not disclose your personal information to the organizations that operate such linked external sites, and we do not review, endorse, or accept responsibility for the privacy practices of those organizations. We encourage you to review the privacy policy of each website you visit. This Privacy Policy applies only to information collected by WADO.
VII. HOW LONG WILL WE STORE YOUR PERSONAL DATA?
We process your personal data for as long as necessary to fulfill the purposes for which the data was collected.
In the case of data processing:
• based on the User's consent – personal data will be processed until the consent is withdrawn;
• if you accept the Terms and Conditions and use the services described therein, until you delete your Candidate Account or send us a statement of withdrawal from the contract for the provision of electronic services;
• in order to ensure compliance with the legal obligations imposed on controllers – personal data will be processed for the period required by law;
• for the purposes of pursuing other legitimate interests of controllers – the data will be processed until your objection (request for data deletion) is taken into account or until the limitation period for claims expires.
Despite the cessation of the above-described purposes, your data may be stored for the period necessary to establish, pursue, and defend claims, which constitutes a legitimate interest of WADO within the meaning of Article 6(1)(f) and Article 9(2)(f) of the GDPR.
In the case of personal data processed on the basis of legal provisions, controllers apply a retention period in accordance with applicable law.
VIII. DATA PROTECTION OFFICER
We take the protection of personal data very seriously, which is why we have appointed a Data Protection Officer in our Companies as part of our activities. The officer can be contacted by post: ul. Prosta 68, 00-838, Warsaw, and via the form available on the Request Service Portal website.
IX. TRANSFER OF DATA TO THIRD COUNTRIES
As a rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the European Union member states and Iceland, Norway, and Liechtenstein.
In some cases, in particular in connection with cooperation with IT solution providers or the need to transfer data to a potential employer, your personal data may be transferred to other third countries or international organizations. In such cases, the personal data safeguards referred to in Articles 46-49 of the GDPR will apply, e.g. in the form of standard data protection clauses adopted by the European Commission.
Data protection framework
The ManpowerGroup Data Protection Framework (including ManpowerGroup Global Inc., Right Management LLC, and ManpowerGroup Talent Solutions LLC) complies with the EU-US Data Protection Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Protection Framework (Swiss-US DPF), as set forth by the US Department of Commerce. ManpowerGroup has certified to the U.S. Department of Commerce that it adheres to the EU-US DPF Principles in its processing of personal data received from the European Union under the EU-US DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-US DPF. ManpowerGroup has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles in its processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. In the event of a conflict between the provisions of this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, those Principles shall prevail. To learn more about the Data Protection Framework (DPF) program and to view our certification of participation, please visit https://www.dataprivacyframework.gov/.
In the context of onward transfers, ManpowerGroup is responsible for the processing of personal data it receives under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, as well as onward transfers to a third party acting on its behalf. ManpowerGroup complies with the EU-U.S. DPF Principles and Swiss-U.S. DPF Principles with respect to all onward transfers of personal data from the EU, the UK, and Switzerland, including the onward transfer liability provisions. ManpowerGroup remains liable under the EU-U.S. DPF Principles, UK Extension to the EU-US DPF, and Swiss-US DPF if a ManpowerGroup agent processes personal data in a manner inconsistent with the EU-US DPF, UK Extension to the EU-US DPF, and Swiss-US DPF, unless ManpowerGroup proves that it is not responsible for the event giving rise to the damage.
The Federal Trade Commission has jurisdiction over ManpowerGroup's compliance with the EU-US DPF, UK Extensions to the EU-US DPF , and Swiss-US DPF. In certain situations, ManpowerGroup may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ManpowerGroup commits to resolving complaints about our collection and use of your personal data under the DPF Principles. Individuals in the EU, UK, and Switzerland with inquiries or complaints regarding our processing of personal data received under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF should first contact ManpowerGroup using the contact details provided.
Under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to refer unresolved complaints about its processing of personal data received under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF-related complaint, or if we have not addressed your DPF-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. Alternative dispute resolution services are provided at no additional cost to you.
Under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to cooperate with and comply with the recommendations of the panel established by the EU data protection authorities (DPA), the UK Information Commissioner's Office (ICO), and the Gibraltar Regulatory Authority (GRA), as well as the Swiss Federal Data Protection and Information Commissioner (FDPIC) on unresolved complaints regarding the processing of employee data received under the EU-US DPF, UK Extension to the EU-US DPF and Swiss-US DPF in the context of employment relationships.
For complaints regarding compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF that have not been resolved by any other mechanism of the EU-US Data Protection Framework, you have the option, under certain conditions, to resort to binding arbitration. For more information, please visit the official EU-US Data Protection Framework website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction
X. HOW WE USE ARTIFICIAL INTELLIGENCE
Some of the services we offer are supported by AI, which may include AI/ML . With the help of AI, we can connect the right people with the best opportunities and help people find jobs more efficiently or prepare them for the job market more easily.
We conduct risk assessments of the AI solutions used by ManpowerGroup and apply human oversight to the maximum extent possible to prevent automated decisions that could have any legal or similarly significant impact on individuals.
We are committed to using transparent, trustworthy, and secure artificial intelligence. In accordance with our AI policy, we always conduct a thorough risk assessment before implementing any AI-based tools to protect the rights of individuals. We are committed to auditing and testing our AI systems to detect and prevent bias.
With artificial intelligence, we can connect people with the right job opportunities, help people find employment more effectively, and increase our overall productivity. We use AI tools in our recruitment procedures to increase the efficiency and effectiveness of the process. AI tools help us with the initial selection of candidates by evaluating their information, for example, to assess candidates' experience or match skills based on predefined criteria (e.g., having a work permit or driver's license) that are relevant to the job requirements. Although artificial intelligence streamlines recruitment processes, the final decision to reject candidates always rests with the recruiter.
Candidate rights
If you wish to request human involvement or share your opinion, you have the right to do so. Instructions on how to exercise this right can be found in the section "RIGHTS OF DATA SUBJECTS."
XI. Essential content of the joint arrangements between the joint controllers
- The joint controllers of your personal data are the companies of the ManpowerGroup:
- ManpowerGroup Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5263493733, REGON: 016863993, KRS: 62137 ("Lead Co-Controller");
- MP Transactions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010204771, REGON: 142057961, KRS: 339387 ("Co-administrator 2");
- MP Services Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5262831360, REGON: 140023580, KRS: 228311 ("Co-administrator 3");
- ManpowerGroup Solutions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010272979, REGON: 142733681, KRS: 373518 ("Co-administrator 4");
- MP Actions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5272474654 REGON: 14015951600000 KRS: 234796 ("Co-administrator 5");
- MP Management Sp. z o.o. with its registered office in Łódź, address: ul. Kopcińskiego 79, 90-033 Łódź, NIP: 7010264572, REGON: 14263040300000, KRS: 0000368086 ("Co-administrator 6");
hereinafter collectively referred to as "WADO".
- Pursuant to Article 26(2), second sentence, of the GDPR, the provision of this information constitutes disclosure of the essential content of the joint arrangements of WADO, whose identity is indicated in point 1 above, with regard to the joint administration of the processing of personal data of the data subject for the purposes and on the legal grounds indicated in the information obligations of WADO and their Privacy Policies.
- In accordance with the joint arrangements of WADO, we hereby inform you that:
- The Lead Joint Controller is responsible for fulfilling the information obligations towards data subjects, which means that it is responsible for meeting the deadlines and content of the information obligation;
- The Lead Co-Controller is responsible for responding to data subjects regarding their requests – which means that it is responsible for meeting deadlines and ensuring that the content of the response complies with the data subject's request to exercise their rights, as well as for the appropriate form of response, including informing the data subject about the actions taken to fulfill the request;
- if a data subject addresses their request to exercise their rights directly to one of the Co-controllers 2-6, each of these Co-controllers is responsible for immediately forwarding the data subject's request to the Lead Co-controller at ;
- The Lead Co-Controller is responsible for exercising the rights of data subjects, i.e., exercising the right of access to personal data, rectification, erasure, or restriction of processing, the right to object to the processing of their personal data, and the right to data portability. – The Lead Joint Controller is responsible for the correct implementation of the request submitted by the data subject, which, as a result of the analysis of the request, was to be implemented and reflected in accordance with the law on the protection of personal data in the given scope;
- The Lead Joint Controller is responsible for notifying the data subject of a personal data breach where the breach is likely to result in a high risk to the rights and freedoms of natural persons;
- Each WADO is responsible for processing personal data in accordance with the provisions of the GDPR.
- The WADOs have established a contact point for data subjects and appointed a joint DPO – the contact point and DPO can be contacted by writing to ul. Prosta 68, 00-838 Warsaw or via the Data Subject Request Service Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Data Subject Request Portal).
- Please be advised that regardless of the arrangements indicated in point 3 above, data subjects may exercise their rights under the GDPR against each of the WADO, which means that a request to exercise rights addressed to each of the WADO is a request submitted in accordance with the GDPR.
XII. How we protect personal data
We maintain administrative, technical, and physical safeguards to protect the personal data we collect from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Such measures are designed to ensure an appropriate level of security, taking into account, on the one hand, the state of the art and, on the other hand, the sensitivity of the personal data and the assessment of potential risks.
XIII. Privacy Policy Updates
From time to time, we may modify this Privacy Policy to reflect changes in technology, privacy practices, and legal updates, or to update the purposes or basis for processing. New versions of the document will include the date of the last update in the header.
XIV. How to Contact Us
If you have any questions or comments about this Privacy Policy or wish to exercise your rights, please submit your request through our Request Service Portal.
Alternatively, you can write to us at the following address:
ManpowerGroup Sp. z o.o.,
ul. Prosta 68, 00-838 Warsaw
Information clause – recruitment
In accordance with Article 13(1) and (2) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of personal data of 27.4.2016 on the protection of natural persons with regard to the processing of their personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ L 2016/679 of the European Parliament and of the Council on the protection of personal data of 27.4.2016 on the protection of natural persons with regard to the processing of their personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ L 2016 of the European Parliament and of the Council. EU L 119 of 4.5.2016 (hereinafter: GDPR) I hereby inform that:
1. In the event that you join the current recruitment process, the Administrator of your personal data will be this Company from the ManpowerGroup Capital Group, (i.e. ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., MP Services Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o. with its registered office at 68 Prosta Street in Warsaw, 00-838, or MP Management Sp. z o.o. with its registered office at 85/87 Sienkiewicza Street, 90-057 in Łódź, from 05.10.2023: at 79 Kopcińskiego Street, 90-033 in Łódź), which is recruiting for the position for which you have applied.
2. If you consent to the processing of personal data in future recruitment processes, the Joint Controllers of your personal data are the Companies that are part of the ManpowerGroup Capital Group (ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., MP Services Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o with its registered office at 68 Prosta Street in Warsaw, 00-838, and MP Management Sp. z o.o. with its registered office at 85/87 Sienkiewicza Street, 90-057 in Łódź, from 05.10.2023: at 79 Kopcińskiego Street, 90-033 in Łódź), hereinafter referred to as: "WADO".
3. Contact with the Administrators and WADO is possible by e-mail at the following e-mail address: [email protected], by phone: 22 50 40 715 and by post: Prosta 68, 00-838, Warsaw
4. The Administrators and WADO have appointed a Data Protection Officer, who can be contacted: by post: Prosta 68, 00-838, Warsaw, as well as via the form available on the website of the Ticket Service Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Report Handling Portal).
5. Your personal data contained in the application documents will be processed for the purposes related to conducting recruitment processes, in particular on the basis of:
a. Article 6(1)(c) of the GDPR, i.e. the legal obligation resulting from the provision of Article 22 (1) of the Labour Code – in the case of seeking employment on the basis of an employment contract.
b. Article 6(1)(a) and Article 9(2)(a) of the GDPR, i.e. consent to the processing of your personal data to a greater extent than it results from Article 22 (1) of the Labour Code and participation in future recruitment processes.
c. Article 6(1)(b) of the GDPR, i.e. taking action at the request of the entitled entity before concluding the agreement – in the case of seeking to commence cooperation on the basis of a civil law contract.
d. Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the Administrator and WADO – primarily for the purpose of verifying your qualifications and possibly pursuing claims or defending against claims.
e. Article 6(1)(a), (f) of the GDPR and Article 9(2)(a) of the GDPR, i.e. the consent or legitimate interest of the Controller or WADO, in order to present your application to our clients who offer work or projects that may be of interest to you or who are interested in your profile.
f. Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the Administrator and WADO – in order to direct marketing content by e-mail, in connection with the consent to send commercial information, including marketing content, to the provided e-mail address.
6. The Administrators and WADO may share your personal data with other recipients in connection with the need to comply with a legal or contractual obligation or to exercise a right under the law or to pursue legitimate interests. The recipients to whom the Controllers and WADO may share your personal data are: our service providers (e.g. providers of IT systems, hosting services, e-mail service providers and other entities through which WADO processes personal data), our clients – your potential employers (we share your data with our clients who offer work or projects that may be of interest to you or who are interested in your profile).
7. Your personal data will not be subject to automated decision-making. WADO will not profile your personal data.
8. As a rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the countries of the European Union and Iceland, Norway and Liechtenstein. Your personal data may be transferred to the United Kingdom of Great Britain and Northern Ireland, against which the European Commission issued an adequacy decision on 28 June 2021. In some cases, in particular in connection with cooperation with IT solution providers or the transfer of data to a potential employer, your personal data may be transferred to other third countries. In such a case, the personal data protections referred to in Articles 46-49 of the GDPR will be applied, e.g. in the form of standard data protection clauses adopted by the European Commission.
9. Your personal data will be processed as part of the ongoing recruitment process for a period of 1 month from the date of completion of the current recruitment process, and in the case of consent to the processing of data for the purposes of future recruitment – for a period of up to 3 years from the submission of the application or until you withdraw your consent to processing – whichever occurs first.
10. Please note that you can withdraw your consent(s) at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal. For evidentiary purposes, please withdraw your consents in writing to the address of the registered office or electronically via the form available on the website of the Request Handling Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Report Handling Portal).
11. You have the right to: access the content of the data and request their rectification, deletion, restriction of processing, the right to transfer personal data and the right to object to the processing of data for reasons related to your particular situation. You also have the right to lodge a complaint with the supervisory authority (UODO, Stawki 2 Street, 00-193 Warsaw).
12. Providing personal data is necessary for the purposes of recruitment. The consequence of not providing this data is the inability to consider your candidacy in the current recruitment process and the inability to participate in future recruitment processes.
Information clause – marketing
In accordance with Article 13(1) and (2) and Article 14(1) and (2) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of personal data of 27.4.2016 on the protection of natural persons with regard to the processing of their personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ L 2016/679 of the European Parliament and of the Council on the protection of personal data, and repealing Directive 95/46/EC, Journal of Laws of the Republic of Poland. EU L 119 of 4.5.2016 (hereinafter: GDPR) I hereby inform that:
- The co-controllers of your personal data are the companies that are part of the ManpowerGroup Capital Group (ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o., MP Services Sp. z o.o. with its registered office at: 68 Prosta Street in Warsaw 00-838, MP Management Sp. z o.o. with its registered office at 79 Kopcińskiego Street, 90-033 Łódź); hereinafter referred to as: WADO.
- WADO has obtained your personal data directly from you or from our partner - a third party who has provided us with your data together with your consent to contact you, or we may have received it from our business partner who has obtained it from publicly available sources.
- In particular, WADO may process the following categories of your personal data, depending on the scope of their disclosure by you or the entity from which WADO has received your data: your name and surname, contact details – phone number and e-mail address, position, employer data (the entity with which you cooperate or which you represent).
- WADO can be contacted: by e-mail: [email protected], by phone: 22 50 40 715, by post: 68 Prosta Street, 00-838 Warsaw.
- WADO has appointed a Personal Data Protection Officer, who can be contacted by: by post: Prosta 68, 00-838 Warsaw or via the Data Subject Notification Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Notification Handling Portal).
- The processing of personal data referred to in point 3 is carried out for the purpose of targeting marketing content (information about ManpowerGroup's offers and services) and, subsequently, for the purpose of negotiating a contract.
- Your personal data may be shared with third party recipients. In particular, these are entities with which contracts have been concluded for the provision of services, e.g. infrastructure, analytical, IT, auditing and consulting services to the extent necessary for the implementation of these agreements. The data may also be made available on the basis of legal provisions, in particular to public entities.
- As a rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the countries of the European Union and Iceland, Norway and Liechtenstein. In connection with the implementation of cooperation with IT solution providers, your personal data may be transferred to the United Kingdom of Great Britain and Northern Ireland or to other third countries. In such a case, the personal data protections referred to in Articles 46-49 of the GDPR will be applied, e.g. in the form of standard data protection clauses adopted by the European Commission or a decision declaring an adequate level of personal data protection.
- Your personal data will be processed until you withdraw your consent or object to the processing of data, and after that time for the period of limitation of claims, if this is in the legitimate interest of WADO within the meaning of Article 6(1)(f) of the GDPR.
- You have the right to request from WADO access to your personal data, their rectification, deletion or restriction of processing, as well as the right to object to data processing, the right to data portability and the right to withdraw consent. The exercise of the above-mentioned rights is possible through the form available on the website of the Data Subject Notification Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Request Handling Portal), by post or by submitting a request in person at WADO's headquarters or any branch.
- You have the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office, if the processing of your personal data violates the provisions on personal data protection.
- No automated decisions will be made against you (decisions without significant human involvement), including your personal data will not be subject to profiling.
Information obligation for contact persons and representatives
Information obligation for contact persons and representatives
Pursuant to Articles 13(1) and (2) and 14(1) and (2) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, OJ L 119 of 4.5.2016. (hereinafter: GDPR), I inform you that:
- the joint controllers of your personal data are companies within the ManpowerGroup (ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o., MP Services Sp. z o.o. with registered office at ul. Prosta 68 in Warsaw, 00-838, MP Management Sp. z o.o. with its registered office at ul. Kopcińskiego 79, in Łódź, 90-033); hereinafter: WADO.
- WADO has obtained your personal data from an entity of which you are an employee, associate or representative or directly from you.
- In particular, WADO may process the following categories of your personal data, depending on the extent to which they are provided by the entity of which you are an employee: your full name, contact details – telephone number and e-mail address, job title, details of your employer (the entity with which you work or which you represent).
- You can contact WADO: by e-mail: [email protected], by telephone: +48 22 50 40 715, or by post: ul. Prosta 68, 00-838 Warsaw.
- WADO has appointed a Data Protection Officer, who can be contacted: by post: ul. Prosta 68, 00-838 Warsaw or via the form available on the Service Portal for Personal Data. (available at https://www.manpowergroup.pl -> Data Protection Officer -> Request Support Portal).
- The processing of personal data referred to in point 3 is carried out for the purpose of:
- performance of a contract concluded with an entity of which you are an employee, collaborator or representative, including in particular for the purpose of negotiation and conclusion of a contract (the basis for the processing of your personal data is Article 6(1)(f) of the GDPR - the legitimate interest of the Controller - or Article 6(1)(b) of the GDPR, if you are a party to the agreement),
- contact, maintaining cooperation, surveying satisfaction with cooperation, as well as conducting market research, improving the quality of services or adjusting services to market needs (the basis for the processing of your personal data is Article 6(1)(f) of the GDPR - the legitimate interest of the Administrator),
- compliance with legal obligations, if such an obligation results from the provisions of law (the legal basis for processing is Article 6(1)(c) of the GDPR),
- establishing, pursuing or defending claims related to the conducted activity (the legal basis for the processing is Article 6(1)(f) of the GDPR).
- Your personal data may be shared with third-party recipients. In particular, such entities include those with whom service contracts have been concluded, e.g. infrastructure, analytical, IT, auditing and consulting services, to the extent that this is necessary for the performance of these contracts. Your personal data may also be made available by law, particularly to public entities.
- As a general rule, your personal data will not be transferred to countries outside the European Economic Area, formed by the countries of the European Union and Iceland, Norway and Liechtenstein. In some cases, in particular, in connection with cooperation with IT solution providers, your personal data may be transferred to third countries or international organisations. In this case, the personal data safeguards referred to in Articles 46-49 of the GDPR will be applied, e.g. in the form of standard data protection clauses adopted by the European Commission or a decision establishing an adequate level of personal data protection.
- Your personal data will be processed for the duration of the contract signed with the entity of which you are an employee, collaborator or representative, and also after the termination of the contract, as long as there is a legitimate interest of WADO within the meaning of Article 6(1)(f) of the GDPR.
- You have the right to request WADO to access, rectify, erase or restrict the processing of your personal data, as well as the right to object to the processing. Your personal data will not be subject to profiling. The above rights can be exercised via the form available on the Service Portal for Personal Data (available at https://www.manpowergroup.pl -> Data Protection Officer -> Request Support Portal), by post or by submitting the request in person at the registered office or any branch of WADO.
- You have the right to lodge a complaint to the supervisory authority – the President of the Personal Data Protection Office, if the processing of your personal data violates the provisions on the protection of personal data.
MY MANPOWER Application Privacy Policy
VERSION DATED 13.01.2026
ManpowerGroup's primary goal is to ensure the confidentiality and security of the personal data of our Clients, Employees, Job Candidates, and Users of the MY MANPOWER application, as well as transparency and compliance with the law in relation to their processing.
The Privacy Policy describes how personal data is protected and processed in accordance with the standards set out in applicable laws.
I. PERSONAL DATA CONTROLLER
The controller of personal data processed for the purposes specified in the Terms and Conditions of Electronic Services of the MY MANPOWER Mobile Application is the Service Provider, i.e. the companies comprising the ManpowerGroup Capital Group, namely ManpowerGroup Sp. z o.o., MP Transactions Sp. z o.o., MP Services Sp. z o.o., ManpowerGroup Solutions Sp. z o.o., MP Actions Sp. z o.o. with its registered office at ul. Prosta 68 in Warsaw, and MP Management Sp. z o.o. with its registered office at ul. Kopcińskiego 79; 90-033 in Łódź (hereinafter: Joint Controllers or JCC).
II. METHODS OF DATA COLLECTION
Your data will be collected:
- directly from you in connection with downloading the MY MANPOWER Mobile Application or in connection with using one or more services or functionalities described in the Terms and Conditions of Electronic Services Provision of the MY MANPOWER Mobile Application (hereinafter: Terms and Conditions)
- indirectly from our databases, from our customers or from state authorities (in particular with regard to the data displayed in the Employee Panel in relation to the functions described in the Terms and Conditions and the data displayed therein, i.e.:
i. preview of the most important Employee data from the employee management system;
ii. display of pay slips for up to the last 12 months;
iii. the ability to download pay slips for up to 12 months in PDF format;
iv. the ability to download PIT-11 in PDF format for the last closed year during which the employee was employed by one of the Service Provider's companies. In order to access PIT-11 in PDF format in the My Manpower application, you must provide written statements in connection with joining the PIT-11 electronic distribution process for companies belonging to the ManpowerGroup Capital Group.
v. the possibility of signing a second and subsequent employment or cooperation agreement in electronic form;
vi. access to frequently asked questions and answers regarding employment and functioning within the ManpowerGroup structure – the set of questions has been expanded to include issues related to the Employee Panel and employment;
vii. access to the Leave tab, which contains information about the number of days and hours of leave remaining to the Employee as of the last day of the previous month;
viii. displaying the following information about the Employee within the Employee Panel:
a. Cost of obtaining income;
b. Information about the senior citizen tax relief (including the value of the tax relief);
c. Information on relief for returning workers from abroad (including the value of the tax relief);
d. Information about the tax relief for a family of four plus (including the value of the tax relief);
e. Income tax settlement address;
f. Type of tax return (regular or electronic);
g. Information about the selected tax office;
h. Active benefits (including the cost of active benefits);
i. Expiration date of medical examinations (valid from – to)
j. Validity date of permits for foreigners (valid from – to);
ix. access to information about the last employment or cooperation contract signed by the Employee and to information about e-contracts available for electronic signing (if any);
x. access to the "Work Schedule" tab, which is used to record the Employee's working time and to plan the work schedule, in accordance with section 8.3 et seq. of the Regulations (if applicable).
III. CATEGORIES OF PERSONAL DATA SUBJECTS WE PROCESS
In connection with the provision of our Services, we process the following data:
- s of the MY MANPOWER Mobile Application,
A User is a job candidate visiting the Application or using one or more services or functionalities of the Application described in the Terms and Conditions, or an employee, contractor, or associate of one of the companies comprising the ManpowerGroup Capital Group;
IV. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We process your data:
- for the purpose of responding to you, i.e. to answer your questions and obtain feedback – in this case, the processing of personal data is based on the legitimate interest of the Joint Controllers, which consists in the need to use your personal data for the purpose of preparing answers to your questions at (Article 6(1)(f) of the GDPR);
- for purposes related to the conclusion and performance of the contract for the provision of the MY MANPOWER Mobile Application services by electronic means, on the terms specified in the Terms and Conditions (Article 6(1)(b) of the GDPR), and as part of these processes we may take the following actions, among others:
i. identification and/or verification of identity;
ii. sending updates and notifications regarding the services received and other related communications;
- for the purpose of possible (only if necessary) investigation and defense against claims – the processing of personal data is based on the legitimate interest of the controller, consisting in the need to defend its rights (Article 6(1)(f) and Article 9(2)(f) of the GDPR);
- for the purpose of conducting statistical and analytical activities related to the functioning of the MY MANPOWER Mobile Application, including using the Google Analytics tool provided by Google Inc. - in this case, personal data is processed on the basis of the legitimate interest of the controller, which is the need to develop and evaluate the services provided (Article 6(1)(f) of the GDPR), and as part of these processes we may take the following actions, among others:
iii. analysis of the use of the application,
iv. analysis of our candidate database,
v. assessment of individual performance and skills, including assessment of job-related skills,
vi. identifying skills shortages,
vii. matching individuals and potential employment opportunities,
viii. pipeline data analysis (recruitment practice trends),
ix. determining the effectiveness of our engagement strategy,
x. determining the effectiveness of our products and services, and
xi. developing and training artificial intelligence (AI) models, including machine learning.
- for the purpose of sending commercial information, including marketing communications, regarding products and services offered by companies in the ManpowerGroup Capital Group - pursuant to Article 6(1)(a) of the GDPR;
- for the purposes of direct marketing by Joint Controllers, including the selection of services tailored to the needs of Users (including profiling) based on cookies and other similar technologies – in this case, data processing by Joint Controllers is based on the legitimate interest of Joint Controllers (Article 6(1)(f) of the GDPR) or consent given (Article 6(1)(a) of the GDPR
- for purposes related to the conclusion and performance of an employment contract or other civil law contract in connection with recruitment, including for the purpose of verifying residence and employment documents and legalizing employment (Article 6(1)(b) and Article 9(b) of the GDPR);
- for the purpose of fulfilling any legal obligations of the employer, resulting, inter alia, from labor law provisions and the obligations of a temporary employment agency resulting from the provisions of the Act on the Employment of Temporary Employees, and for purposes related to the performance of such contracts – Article 6(1)(c) and Article 9(b) of the GDPR;
- to provide HR services, including the management of benefit programs, travel and expenses, employee evaluations, and disciplinary actions;
- to take action at the request of an authorized entity prior to the conclusion of a contract – in the case of seeking to commence cooperation and subsequently cooperating on the basis of a civil law contract (Article 6(1)(b) of the GDPR).
- to pursue the legitimate interests of the Joint Controllers, which may include, among others, ensuring compliance and accountability in accordance with the GDPR (Article 6(1)(f) of the GDPR), and in particular:
i. conducting audits of our processes and documentation;
ii. protecting against fraud, identifying and seeking to prevent fraud, misleading practices, and other illegal activities, claims, and other liabilities;
iii. enhancing the security of our networks and information systems;
iv. complying with and enforcing applicable legal requirements, exercising or defending legal claims, relevant industry standards, contractual obligations, and our policies;
- to provide recruitment services, including informing about ongoing recruitment processes, verifying qualifications, experience, employment opportunities, and recommending candidates to clients (Article 6(1)(a), (b), or (f) of the GDPR), as well as:
i. coaching, providing feedback, analysis, advice, and guidance to support you in managing and developing your career;
ii. tailoring and personalizing the support we offer based on qualifications and other criteria;
- for the purpose of conducting the recruitment process in connection with the voluntary provision of special categories of data in accordance with Article 9(2)(a) of the GDPR.
- in order to provide candidates with information on the initial salary or salary ranges for a given position, the applicable remuneration regulations/provisions of the collective agreement (if applicable), as well as the rules for promotion and criteria for salary progression (Article 6(1)(c) of the GDPR), in connection with the provisions of Directive (EU) 2023/970 of the European Parliament and of the Council and the provisions of the Act of 1(c) of the GDPR, in connection with the provisions of Directive (EU) 2023/970 of the European Parliament and of the Council and the provisions of the Act of June 26, 1974, Labor Code),
We may also use this information for other purposes, for which you will receive a separate information clause or a supplement to this clause.
Legitimate interest of WADO
Depending on applicable regulations, WADO has the right to process personal data for specific legitimate interests, which may include some or all of the following:
i. improving, modifying, personalizing, or otherwise enhancing our services/communications for the benefit of our customers, candidates, and associates, for example, through the use of technical measures such as call transcription features;
ii. identifying and preventing fraud;
iii. enhancing the security of our networks and information systems;
iv. increasing our understanding of how visitors and users use our websites and applications;
v. determining the effectiveness of promotional and advertising campaigns;
vi. using AI support, as described in the Terms and Conditions.
Whenever we process data for these purposes, we take care to protect your rights. You can object to such processing, and you can do so by contacting us as indicated below in the "How to contact us" section. Please note that if you exercise your right to object, this may affect our ability to provide and deliver services to you.
V. RIGHTS OF DATA SUBJECTS
You have the following rights:
• the right to withdraw your consent to the processing of your personal data;
• the right to access your personal data;
• the right to request the rectification of your personal data;
• the right to request the deletion of your personal data;
• the right to request restriction of the processing of your personal data;
• the right to object to the processing of your personal data;
• the right to request the transfer of your personal data;
The above rights can be exercised using the form available at on the Request Service Portal . For those who do not use the Internet, the Joint Controllers provide the option of submitting a request by post: ul. Prosta 68, 00-838, Warsaw, or by delivering the request in person to the headquarters or any branch of the Joint Controllers.
After you submit your request, we may contact you directly or through our secure Request Service Portal to verify your email address and then your identity before we disclose, modify, or delete your data. We are only required to respond to verifiable and reasonable requests. If we cannot verify your identity, we may ask you for additional verification information. We will not use this information for anything other than verification. If the content of your request is unclear, we may also ask you for additional information regarding the content and scope of the request.
If we are unable to verify your identity or determine the content of your request with sufficient certainty to respond to your request, we will promptly notify you and explain why we cannot verify your identity or process your request.
Privacy requests submitted by a representative
You may appoint an authorized representative to exercise your rights on your behalf. If an authorized representative submits a request on your behalf, they must also provide a document signed by you authorizing them to submit the request on your behalf. In addition, we may ask both you and your representative to follow the identity verification procedure described above.
Processing of data relating to minors
We respect the privacy of children. Our websites and services are generally not intended for or directed at children. If you are a parent or guardian, please contact us if you believe we may have collected information from your child, and we will investigate and take appropriate action.
In addition to the rights described above, you also have the right to lodge a complaint with the President of the Personal Data Protection Office.
VI. RECIPIENTS OF PERSONAL DATA
In order to ensure the proper provision of services, your personal data may be transferred to:
• our Clients – entities seeking job candidates who post job offers on our website;
• our Suppliers – entities providing us with infrastructure, IT, technical, maintenance, administrative, legal, tax, auditing, and other services;
- affiliated entities;
• third parties from whom cookies or other technologies originate, including Google Inc. (the provider of Google Analytics).
Below, we provide more detailed information in this regard.
We may disclose some personal data to suppliers who provide services on our behalf, in accordance with our instructions, in order to provide you with our Websites and services. These suppliers may include, among others, IT and cloud service providers. We strive to limit this data to the level necessary to perform specific tasks. We do not authorize providers who process data on our behalf to use or disclose this information unless it is necessary to perform services or comply with legal requirements. Personal data will not be sold, rented, distributed, or shared with providers for their own commercial purposes, including for their direct marketing purposes.
We may also disclose your personal data in particular: (i) to our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job openings or an interest in hiring our candidates; and (iii) with others we work with, such as consultants providing career support services or employment providers who work with us on recruitment and hiring (iv) if you use talent management services, we may disclose the status or progress of your program to the client—a potential employer—along with any relevant results of the recruitment process.
In addition, we may disclose personal information about you (i) if required by law or legal process; (ii) to law enforcement or other government officials pursuant to 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 into suspected or actual fraud or illegal activity. We also reserve the right to transfer the personal data we hold about you in the event of a sale or transfer of all or part of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
Links to external tools and resources
We may provide links to external websites operated by organizations not affiliated with WADO. We do not disclose your personal information to the organizations that operate such linked external sites, and we do not review, endorse, or accept responsibility for the privacy practices of those organizations. We encourage you to review the privacy policy of each website you visit. This Privacy Policy applies only to information collected by WADO.
VII. HOW LONG WILL WE STORE YOUR PERSONAL DATA?
We process your personal data for as long as necessary to fulfill the purposes for which the data was collected.
In the case of data processing:
• based on the User's consent – personal data will be processed until the consent is withdrawn;
• in the case of accepting the Terms and Conditions and using our services described therein, until the Account in the Application is deleted or a statement of withdrawal from the concluded contract for the provision of electronic services is sent to us;
• in order to ensure compliance with the legal obligations imposed on controllers – personal data will be processed for the period required by law;
• for the purposes of pursuing other legitimate interests of the Joint Controllers – the data will be processed until your objection (request for data deletion) is taken into account or until the limitation period for claims expires.
Despite the cessation of the above-described purposes, your data may be stored for the period necessary to establish, pursue, and defend claims, which constitutes a legitimate interest of WADO within the meaning of Article 6(1)(f) and Article 9(2)(f) of the GDPR.
In the case of personal data processed on the basis of legal provisions, controllers apply a retention period in accordance with applicable law.
VIII. DATA PROTECTION OFFICER
We take the protection of personal data very seriously, which is why we have appointed a Data Protection Officer in our Companies as part of our activities. The officer can be contacted by post: ul. Prosta 68, 00-838, Warsaw, and via the form available on the Request Service Portal website.
IX. TRANSFER OF DATA TO THIRD COUNTRIES
As a rule, your personal data will not be transferred to countries outside the European Economic Area, which consists of the European Union member states, Iceland, Norway, and Liechtenstein. In some cases, in particular in connection with cooperation with IT solution providers or the need to transfer data to a potential employer, your personal data may be transferred to other third countries or international organizations. In such cases, the personal data safeguards referred to in Articles 46-49 of the GDPR will be applied, e.g. in the form of standard data protection clauses adopted by the European Commission.
Data protection framework
The ManpowerGroup Data Protection Framework (including ManpowerGroup Global Inc. Right Management LLC., and ManpowerGroup Talent Solutions LLC) complies with the EU-US Data Protection Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Protection Framework (Swiss-US DPF), as determined by the US Department of Commerce. ManpowerGroup has certified to the U.S. Department of Commerce that it adheres to the EU-US DPF Principles in its processing of personal data received from the European Union under the EU-US DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-US DPF. ManpowerGroup has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles in its processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. In the event of a conflict between the provisions of this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, those Principles shall prevail. To learn more about the Data Protection Framework (DPF) program and to view our certification of participation, please visit https://www.dataprivacyframework.gov/.
In the context of onward transfers, ManpowerGroup is responsible for the processing of personal data received under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, as well as onward transfers to a third party acting on its behalf. ManpowerGroup complies with the EU-U.S. DPF Principles and Swiss-U.S. DPF Principles with respect to all onward transfers of personal data from the EU, the UK, and Switzerland, including the provisions on liability for onward transfers. ManpowerGroup remains liable under the EU-U.S. DPF Principles, the UK Extension to the EU-US DPF and the Swiss-US DPF if a ManpowerGroup agent processes personal data in a manner inconsistent with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, unless ManpowerGroup proves that it is not responsible for the event giving rise to the damage.
The Federal Trade Commission has jurisdiction over ManpowerGroup's compliance with the EU-US DPF, UK Extension to the EU-US DPF, and Swiss-US DPF. In certain situations, ManpowerGroup may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ManpowerGroup commits to resolving complaints about our collection and use of your personal data under the DPF Principles. Individuals in the EU, UK, and Switzerland with inquiries or complaints regarding our processing of personal data received under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF should first contact ManpowerGroup using the contact details provided.
Under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to refer unresolved complaints regarding the processing of personal data received under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF-related complaint, or if we have not addressed your DPF-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. Alternative dispute resolution services are provided at no additional cost to you.
Under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to cooperate with and comply with the recommendations of a panel established by the EU data protection authorities (DPAs), the UK Information Commissioner's Office (ICO), and the Gibraltar Regulatory Authority (GRA), as well as the Swiss Federal Data Protection and Information Commissioner (FDPIC) on unresolved complaints regarding the processing of employee data received under the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF in the context of employment relationships.
For complaints regarding compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF that have not been resolved by any of the other mechanisms of the EU-US Data Protection Framework, you have the option, under certain conditions, to resort to binding arbitration. For more information, please visit the official EU-US Data Protection Framework website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction
X. HOW WE USE ARTIFICIAL INTELLIGENCE
Some of the services we offer are supported by AI, which may include AI/ML. With the help of AI, we can connect the right people with the best opportunities and help people find jobs more efficiently or prepare them for the job market more easily.
We conduct risk assessments of the AI solutions used by ManpowerGroup and apply human oversight to the maximum extent possible to prevent automated decisions that could have any legal or similarly significant effects on individuals.
We are committed to using transparent, trustworthy, and secure artificial intelligence. In accordance with our artificial intelligence policy, we always conduct a thorough risk assessment before implementing any AI-based tools to protect the rights of individuals. We are committed to auditing and testing our AI systems to detect and prevent bias.
With artificial intelligence, we can connect people with the right job opportunities, help people find employment more effectively, and increase our overall productivity. We use AI tools in our recruitment procedures to increase the efficiency and effectiveness of the process. AI tools help us with the initial selection of candidates by evaluating their information, for example, to assess candidates' experience or match skills based on predefined criteria (e.g., having a work permit or driver's license) that are relevant to the job requirements. Although artificial intelligence streamlines recruitment processes, the final decision to reject candidates always rests with the recruiter.
Candidate rights
If you wish to request human involvement or share your opinion, you have the right to do so. Instructions on how to exercise this right can be found in the "Rights of data subjects" section below.
XI. Main content of the joint arrangements between the joint controllers
1. The joint controllers of your personal data are the companies of the ManpowerGroup:
a. ManpowerGroup Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5263493733, REGON: 016863993, KRS: 62137 ("Lead Joint Controller");
b. MP Transactions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010204771, REGON: 142057961, KRS: 339387 ("Co-administrator 2");
c. MP Services Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5262831360, REGON: 140023580, KRS: 228311 ("Co-administrator 3");
d. ManpowerGroup Solutions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010272979, REGON: 142733681, KRS: 373518 ("Co-administrator 4");
e. MP Actions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5272474654 REGON: 14015951600000 KRS: 234796 ("Co-administrator 5");
f. MP Management Sp. z o.o. with its registered office in Łódź, address: ul. Kopcińskiego 79, 90-033 Łódź, NIP: 7010264572, REGON: 14263040300000, KRS: 0000368086 ("Co-administrator 6");
hereinafter collectively referred to as "WADO".
2. Pursuant to Article 26(2), second sentence, of the GDPR, the provision of this information constitutes disclosure of the essential content of the joint arrangements of WADO, whose identity is indicated in point 1 above, with regard to the joint administration of the processing of personal data of the data subject for the purposes and on the legal grounds indicated in the information obligations of WADO and their Privacy Policies.
3. In accordance with the joint arrangements of WADO, we hereby inform you that:
• The Lead Joint Controller is responsible for fulfilling the information obligations towards data subjects, which means that it is responsible for meeting the deadlines and content of the information obligation;
• The Lead Co-Controller is responsible for responding to data subjects regarding their requests – which means that it is responsible for meeting deadlines and ensuring that the content of the response complies with the data subject's request to exercise their rights, as well as for the appropriate form of response, including informing the data subject about the actions taken to fulfill the request;
• if a data subject addresses their request to exercise their rights directly to one of the Co-controllers 2-6, each of these Co-controllers is responsible for immediately forwarding the data subject's request to the Lead Co-controller;
• The Lead Co-Controller is responsible for exercising the rights of data subjects, i.e., exercising the right of access to personal data, rectification, erasure, or restriction of processing, the right to object to the processing of their personal data, and the right to data portability. – The Lead Joint Controller is responsible for the correct fulfillment of the request submitted by the data subject, which, as a result of the analysis of the request, was to be fulfilled and reflected in accordance with the law on the protection of personal data in the given scope;
• The Lead Joint Controller is responsible for notifying the data subject of a personal data breach where the breach is likely to result in a high risk to the rights and freedoms of natural persons;
• Each WADO is responsible for processing personal data in accordance with the provisions of the GDPR.
4. The WADOs have established a contact point for data subjects and appointed a joint DPO – the contact point and DPO can be contacted by writing to ul. Prosta 68, 00-838 Warsaw or via the Data Subject Request Service Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Data Subject Request Portal).
5. Please be advised that regardless of the arrangements indicated in point 3 above, data subjects may exercise their rights under the GDPR against each of the WADO, which means that a request to exercise rights addressed to each of the WADO is a request submitted in accordance with the GDPR.
XII. How we protect personal data
We maintain administrative, technical, and physical safeguards to protect the personal data we collect from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Such measures are designed to ensure an appropriate level of security, taking into account, on the one hand, the state of the art and, on the other hand, the sensitivity of the personal data and the assessment of potential risks.
XIII. Updates to the Privacy Policy
From time to time, we may modify this Privacy Policy to reflect changes in technology, privacy practices, and legal updates, or to update the purposes or basis for processing. New versions of the document will include the date of the last update in the header.
XIV. How to Contact Us
If you have any questions or comments about this Privacy Policy or wish to exercise your rights, please submit your request via our Request Service .
Alternatively, you can write to us at the following address:
ManpowerGroup Sp. z o.o.,
ul. Prosta 68, 00-838 Warsaw
Data transfer - Data Privacy Framework
Data Privacy Framework
ManpowerGroup (including ManpowerGroup Global Inc., Right Management LLC and ManpowerGroup Talent Solutions LLC) complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce. ManpowerGroup has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-US DPF. ManpowerGroup has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In the context of onward transfers, ManpowerGroup is accountable for the processing of personal data it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. ManpowerGroup remains liable under the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles if ManpowerGroup’s agent processes personal information in a manner inconsistent with the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, unless ManpowerGroup proves that it is not responsible for the event giving rise to damage.
The Federal Trade Commission has jurisdiction over ManpowerGroup’s compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF. In certain situations, ManpowerGroup may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ManpowerGroup commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact ManpowerGroup using the information provided in the How to Contact Us section of this notice.
In compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ManpowerGroup commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.
For complaints regarding EU-US DPF, the UK Extension to the EU-US DPF, and Swiss-US DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction
Legitimate Interest
ESSENTIAL CONTENT OF THE JOINT AGREEMENTS OF JOINT CONTROLLERS
1. The joint controllers of your personal data are companies from the ManpowerGroup:
a) ManpowerGroup Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5263493733, REGON: 016863993, KRS: 62137 ("Lead Joint Controller");
b) MP Transactions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010204771, REGON: 142057961, KRS: 339387 ("Co-administrator 2");
c) MP Services Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5262831360, REGON: 140023580, KRS: 228311 ("Co-administrator 3");
d) ManpowerGroup Solutions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 7010272979, REGON: 142733681, KRS: 373518 ("Co-administrator 4");
e) MP Actions Sp. z o.o. with its registered office in Warsaw, address: ul. Prosta 68, 00-838 Warsaw, NIP: 5272474654 REGON: 14015951600000 KRS: 234796 ("Co-administrator 5");
f) MP Management Sp. z o.o. with its registered office in Łódź, address: ul. Kopcińskiego 79, 90-033 Łódź, NIP: 7010264572, REGON: 14263040300000, KRS: 0000368086 ("Co-administrator 6");
hereinafter collectively referred to as "WADO".
2. Pursuant to Article 26(2), second sentence, of the GDPR, the provision of this information constitutes disclosure of the essential content of the joint arrangements of WADO, whose identity is indicated in point 1 above, with regard to the joint control of the processing of personal data of the data subject for the purposes and on the legal grounds indicated in the information obligations of WADO and their Privacy Policies.
3. In accordance with the joint arrangements of WADO, we hereby inform you that:
• The Lead Joint Controller is responsible for fulfilling the information obligations towards data subjects, which means that it is responsible for meeting the deadlines and content of the information obligation;
• The Lead Joint Controller is responsible for responding to data subjects regarding their requests – which means that it is responsible for meeting deadlines and ensuring that the content of the response complies with the data subject's request to exercise their rights, as well as for the appropriate form of response, including informing the data subject about the actions taken to fulfil the request;
• if a data subject addresses their request to exercise their rights directly to one of the Joint Controllers 2-6, each of these Joint Controllers is responsible for immediately forwarding the data subject's request to the Lead Joint Controller;
• The Lead Joint Controller is responsible for exercising the rights of data subjects, i.e. exercising the right of access to personal data, rectification, erasure or restriction of processing, the right to object to the processing of their personal data and to transfer it – The Lead Joint Controller is responsible for the correct implementation of the request submitted by the data subject, which, following analysis of the request, was to be implemented and reflected in accordance with the law on the protection of personal data in the given area;
• The Lead Joint Controller is responsible for notifying the data subject of a personal data breach where the breach is likely to result in a high risk to the rights and freedoms of natural persons;
• Each WADO is responsible for processing personal data in accordance with the provisions of the GDPR.
4. The WADOs have established a contact point for data subjects and appointed a joint DPO – the contact point and DPO can be contacted by writing to ul. Prosta 68, 00-838 Warsaw or via the Data Subject Request Service Portal (available at https://www.manpowergroup.pl -> Data Protection Officer -> Data Subject Request Portal).
5. Please be advised that, regardless of the arrangements indicated in point 3 above, data subjects may exercise their rights under the GDPR against each of the WADO, which means that a request to exercise rights addressed to each of the WADO is a request submitted in accordance with the GDPR.
