PeopleScout Privacy Notice

PEOPLESCOUT PRIVACY NOTICE

PeopleScout Ltd and our subsidiaries, affiliates and parent company, TrueBlue, Inc. (collectively, “PeopleScout”, “we”, “our”, or “us”) value your privacy. In our provision of services to employees, applicants, and customers, we are committed to processing your personal information in a fair, transparent, and lawful manner.

This Privacy Notice (“Notice”), together with our Terms & Conditions explains, among other things, what information we collect, how we use the information we collect (as well as the human resources data transferred to us for processing on behalf of our customers), and how you can instruct us to limit the use of that information.

This Notice also describes your choices and rights regarding use, access, correction, erasure, restriction of processing, portability, and rights regarding automated decision making of or based on your Personal Data.

Please read the Notice carefully to understand our policies and practices regarding your personal data and how we will process it. By using PeopleScout’s Services (as defined below) you acknowledge you have read and understood this Notice.

Scope of this Notice

This Notice applies to any processing of personal information that is collected, used, or disclosed: (a) through this Website; and (b) in connection with any of our recruitment, sales, marketing, advertising or employment activities.

This Notice does not apply to the practices or policies of third parties that are not a parent, subsidiary, and/or affiliate of PeopleScout.

Applicants for roles with PeopleScout and employees of PeopleScout may also receive separate notices relevant to their Personal Data.

Definitions

The following Definitions apply throughout this Notice.

Analytics Information – Means information including but not limited to your IP address, login information, browser, operating system and platform, internet service provider, location, time zone setting, browser plug-in types and version, the type of cellular phone you use, unique device identifiers, and cellular service provider.
PeopleScout Services – Means Recruitment Process Outsourcing (RPO) and Recruiter on Demand (ROD) services and the associated sales, marketing, and advertisement of such services in which PeopleScout recruits candidates for third-party clients for employment with such clients.
PeopleScout Clients – Means any third party organization that PeopleScout has contracted with to provide the PeopleScout Services.
Personal Data – Means information that may directly or indirectly identify you as a natural person.
Process – Means, in regards to Personal Data, any collection, maintenance, transmission, storage, retention or other use of Personal Data.
Website - Means the website(s) operated by PeopleScout, including PeopleScout.com, PeopleScout.co.uk, and PeopleScout.com.au.

Data Protection Principles

PeopleScout is committed to processing your Personal Data in accord with the following principles:

Using your Personal Data in a lawful, fair, and transparent way;
Collecting Personal Data only for valid purposes that we have clearly explained to you and not using such Personal Data in any way that is incompatible with those purpose;
Collecting Personal Data relevant to those purposes we have told you about and limited only to those purposes;
Keeping accurate and up to date records on your Personal Data;
Keeping your Personal Data for as long as necessary for the purposes of which we collect your personal data or have told you about; and
Keeping your Personal Data secure.

Individuals We May Collect Information From

PeopleScout may process Personal Data on the following categories of individuals:

Applicants – PeopleScout may process Personal Data on individuals that apply for a position with PeopleScout and/or a PeopleScout Client.
Employees – PeopleScout may process Personal Data on individuals that become employees of PeopleScout.
Customers – PeopleScout may process Personal Data on individuals acting in their capacity as an employee, representative, and/or agent for current, former, and/or prospective PeopleScout Clients.
Vendors – PeopleScout may process Personal Data on individuals acting in their capacity as an employee, representative, and/or agent for current, former, and/or prospective PeopleScout third-party vendors, suppliers, and/or service providers.
Website Users – PeopleScout may collect and maintain Personal Data on individuals who visit, use, or otherwise interact with our Website(s).

What Information We May Collect and Process

PeopleScout may process the following categories of Personal Data.

Information You Affirmatively Provide. When you register for or use PeopleScout’s Services , whether through the PeopleScout website, a PeopleScout or PeopleScout Client managed applicant tracking system, email, text message, phone, or in person, you may be required to provide information including but not limited to:

1. Contact information, including but not limited to:

Address
E-mail address
Telephone number

2. Personal information, including but not limited to:

National ID number
Gender
Marital status
Date of birth
Maiden name (if applicable)
Family information, including family members, dependents, parents, and next of kin names, dates of births, and/or contact information
Tax Identification Number
National Health Care information

3. Recruitment and Employment information, including but not limited to:

CV, Resume, or application materials
Education history
Employment history
Professional qualifications
Relevant skills, certifications
Interview and assessment notes
Citizenship and/or work authorization information
Compensation and/or payroll information

The information described above is information that you specifically provide. Other information that you specifically provide includes, but is not limited to, the content of emails, text messages, letters, phone calls, and comments you send, place, or post to PeopleScout or our employees, agents, affiliates, or representatives. While you are under no obligation to provide PeopleScout with Personal Data, Personal Data is required in the event you would like to utilize and benefit from the PeopleScout Services. We expect you to provide accurate information to the best of your ability.

Sensitive Information. Sensitive Information is data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. We may collect this information for specific purposes in fulfilling one’s employment with PeopleScout or to perform the PeopleScout Services for a PeopleScout Client. We will collect this information to accommodate and/or comply with all legal obligations.

Information Supplied By Others. We may get Personal Data about you from third parties. For example, other users of the website may provide us with Personal Data about you. This helps us to update, expand and analyze our records. We may obtain information publicly available career sites. Additionally, you may choose to provide us with information processed by a third party site, such as a job search or social media site. We may use this information to determine which employment opportunities may be a good match for you based on your skills, experience, and/or feedback from our PeopleScout Clients or other third parties. If you provide us Personal Data about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Automatically Collected Information. In addition to the information described above, we may collect information automatically regarding your use of the Website. This information includes but is not limited to, your IP address, login information, browser, operating system and platform, internet service provider, location, time zone setting, browser plug-in types and version, the type of cellular phone you use, unique device identifiers, and cellular service provider (collectively, “Analytics Information”). We may also collect and use information and statistics that describe the demographics, usage and/or characteristics of our users as part of the analytics information.

To learn more about information automatically collected through use of our Website, please visit our Cookie Notice.

How We Use the Information We Collect

PeopleScout processes Personal Data to provide the PeopleScout Services, including the management of our Website and related activities. We will use your Personal Data in the following ways:

Information you give us or supplied by others: We will use this information to:

Provide the PeopleScout Services to you and/or the PeopleScout Clients;
Provide and/or administer internal operations to support the PeopleScout Services;
Process employment applications for positions you may apply for with PeopleScout or PeopleScout Clients;
Administer our account with you;
Provide information on PeopleScout Services you have requested;
Send e-mails and other promotional communication about PeopleScout and the PeopleScout Services, including marketing, advertising, promotional, and thought leadership material;
Comply with all applicable laws, rules and regulations;
Respond to requests from you, including your exercising of any rights;
To match candidates and PeopleScout Clients with job opportunities;
Manage our employee workforce;
Manage any payment and/or compensation;
Manage PeopleScout’s internal business operations; and
Ensure that the content on our Website is presented in the most efficient manner.

Automatically Collected Information: we will use this information to:

Administer our Website;
Keep our Website safe and secure;
Improve the Website;
Perform internal operations including troubleshooting, data analytics, testing, research, statistics and survey purposes; and
Allow you to participate in the interactive features of the PeopleScout Services, when you choose to do so.

If you have already provided Personal Data to PeopleScout, we may additional automatically collect information on your website activity.

Who We Share Your Information With

We may disclose Personal Data and Analytics Information:

To any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who may support us in our data processing and provision of the PeopleScout Services;
To service providers and other third parties for any lawful purpose, including without limitation, to manage requests and questions from you, personalize or enhance transactions, verify, process, store, enforce, investigate and/or collect actual or potential transactions, or assist or respond to our consultants including, but not limited to, auditors and lenders;
To service providers assisting in providing the PeopleScout Services, including support for recruitment, interviewing, applicant tracking, resume/CV management, infrastructure management, platform management, application services, marketing, data analytics, skill assessments, and drug and background screening;
To our PeopleScout Clients so that you may be considered for employment opportunities with them;
As authorized by you or consented to by your legal representative;
To government regulators, law enforcement authorities or alleged victims of identity theft, including voluntary disclosures;
To law enforcement of any illegal activity or material we suspect or discover on, through, or otherwise relating to our services and provide law enforcement officials with all requested information about the user account from which the alleged or actual illegal activity or material originated;
To companies that you work for, or that you are considered to work for;
To provide you with the PeopleScout Services and to respond to your requests;
In the event of a merger, acquisition, reorganization, restructuring, assignment, sale of assets, or bankruptcy or insolvency;
To exercise our rights or to assist third parties in defending their rights under applicable laws, including, without limitation, to assert, defend, and enforce our property rights and to respond to legal process;
To communicate or market to you about the PeopleScout Services or to other products or services PeopleScout or its affiliates or subsidiaries offer or believe that you might be interested in;
If you have previously provided information to PeopleScout, to third parties for PeopleScout or third party advertising for advertising and marketing purposes;
Analytics and search engine providers that assist us in the improvement and optimization of our Website;
Business partners who may provide services to you and with whom we have entered into agreements, in relation to the processing of your Personal Data; or
For other reasons that are not prohibited by law.

We reserve the right to process Personal Data and Analytics Information for any lawful purpose or to prevent harm to us or others.

Lawful Basis for Processing (EU, EEA, and Switzerland Users)

PeopleScout will only process Personal Data of individuals when legally permitted and with a lawful purpose.

PeopleScout will process Personal Data for EU, EEA, and Switzerland individuals only (a) when the processing is in PeopleScout’s legitimate interest/purpose and not overridden by your rights; (b) when we need to process Personal Data to perform a contract with you; (c) when PeopleScout has your consent to do so; and/or (d) if PeopleScout has a legal obligation to collect such Personal Data. The specific lawful basis will depend on the type of Personal Data and the context in which we collected such information.

Legitimate Purpose. PeopleScout may process Personal Data in the legitimate interest of PeopleScout.

PeopleScout will only use legitimate interest to the extent processing is necessary for PeopleScout or a third party (including PeopleScout Clients’) legitimate interests, provided that such legitimate interests are not overridden by your interests, rights, and freedoms. This includes but is not limited to providing, managing, and improving the PeopleScout Services; ensuring effective general human resources and business administration; providing recruitment; undertaking sales, marketing, and advertising efforts; and responding to communications.

Performance of a Contract. PeopleScout may process Personal Data in performance of a contract, either between you or a PeopleScout Client.

Consent. If PeopleScout requires your consent for processing Personal Data, we will provide you with the necessary details to allow you consider whether you wish to consent.

For further information concerning the legal basis on which we collect and use Personal Data, please contact us via the information in the “Contact Us” section below.

Your Rights (EU, EEA, and Switzerland Users)

If you are a user of the PeopleScout Services and/or Website from the European Union, European Economic Union, and/or Switzerland, your privacy rights include the following:

Right to Access. You have the right to request access to the Personal Data we hold for you. You may obtain confirmation whether or not we are processing your Personal Data and, if we are processing your Personal Data, access to such Personal Data. You have the right to obtain a copy of the Personal Data we hold on you.
Right to Rectification. You have the right for any inaccurate Personal Data to be rectified and/or corrected. You have the right to have incomplete Personal Data we may have, completed. Upon your request, we will update any inaccurate and/or incomplete Personal Data to ensure such Personal Data is accurate and/or complete.
Right to Erasure and the “Right to be Forgotten”. You have, in certain circumstances, the “right to be forgotten” and to request erasure of your Personal Data. Such right is subject to our obligation to maintain Personal Data under applicable laws, retain Personal Data in connection with the establishment, defense, or exercise of legal claims, or as otherwise set forth in this Notice.
Right to Restrict Processing. You have the right to request restriction or suppression of your Personal Data in certain circumstances. You also have the right to object to any direct marketing from us.
Right to Objection. You have the right to object to the processing of your Personal Data in certain circumstances. However, we may be entitled to continue processing your Personal Data based on our legitimate interests (provided we have a compelling legitimate interest for the processing and such interest does not unduly interfere with your rights, interests or freedoms) or to establish, exercise, or defend legal claims.
Right to Data Portability. You have the right to request a copy of the Personal Data you have provided us in a machine-readable format or to transfer certain personal data to another party.
Rights Related to Automated Decision Making. You may contest any automated decisions made about you where such decision has a legal or similar effect.

You may access, correct, or request deletion of your Personal Data by sending an email
to privacy@trueblue.com or by completing the attached form. We acknowledge that you have the right to access your Personal Data. In some circumstances, we have no direct relationship with the individuals whose personal data we process, in which case your query may need to be directed to a PeopleScout Client or to another organization which may have provided your data to us. If requested to remove data we will respond within a reasonable timeframe and in compliance with all applicable laws.

You may sign-up to receive emails from us on some of our websites. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you, or by sending an email to privacy@trueblue.com or by completing the attached form.

You may opt out of certain other communications that we provide by following the instructions for opting out in those communications.

If your request or concern is not satisfactorily resolved by us, you may contact your local data protection authority.

Your Rights (California Residents)

If you are a user of the TrueBlue Services and/or Website and a resident of California, the California Consumer Privacy Act (CCPA) gives you certain rights regarding your personal information depending on the your relationship (including employment relationship and employment status) with PeopleScout and how you utilize the PeopleScout Services. Your rights include the following:

Right to be Informed: You have the right to be informed of: (a) the categories of Personal Data we collect about you; (b) the categories of Personal Data collection sources; (c) the business or commercial purposes for processing your Personal Data; and (d) the categories of third parties we share such Personal Data. The foregoing is set for in this Notice.
Right to Access: You have the right to request that we disclose certain Personal Data to you about our Personal Data processing over the past 12 months.
Right to Delete: In certain circumstances and subject to certain exceptions, you may have the right to request that your Personal Information is deleted.
Right to opt-out of Sales of Personal Data: CCPA gives you the right to opt out of the sale of your Personal Information. PeopleScout does not sell Personal Data to third parties.
Right to Non-Discrimination: We will not discriminate against you when you exercise your privacy rights under the CCPA and we will not (a) deny you goods or services; (b) charge you different prices or rates for goods or services; or (c) provide you with a different level of quality of good or services. However PeopleScout make take all necessary steps in compliance with applicable law to verify a requestor’s identity.

To exercise your rights, please may use the contact information listed in the “Contact Us” section below, or complete the Data Request Form.

Third Party and Service Providers

PeopleScout uses a variety of third parties and third-party service providers in connection with the PeopleScout Services (collectively, “Third Party Services”). Third Party Services may process Personal Data or Analytics Information in the ways described in this Notice. Third Party Services may have their own terms of use or privacy policies that may apply to you, and that describe how Third Party Services process your Personal Data or Analytics Information. These terms of use, privacy policies, and practices by Third Party Services are not described in this Notice.

While all of the Third-Party Services PeopleScout uses are not described in this Notice, examples of Third-Party Services it uses or may use include:

Google, for the Google Analytics service, including to help PeopleScout to collect and use analytics information in connection with the Services. To learn more about the Google Analytics privacy practices, visit http://www.google.com/intl/en/policies/privacy/ and http://www.google.com/policies/privacy/partners/.

Facebook, including to help authenticate you, log you into your account, or to share personal or profile information with the Services. To learn more about Facebook privacy practices, visit https://www.facebook.com/policy.php and https://www.facebook.com/full_data_use_policy.

Location Based Information

You may opt-in to Services that gather location-based information (“LBI”). If you opt-in to Services with LBI sharing, we may obtain your LBI Personal Data from your mobile device to provide the PeopleScout Services to you, for the purposes allowed for in this Notice, and for other purposes, including, without limitation, determining your proximity to a future job opportunity.

We may aggregate and use your LBI for any legal purpose, which may include, without limitation, reporting usage, adoption of LBI, and improvement of the PeopleScout Services. LBI services are available on many major wireless carriers in the United States but may not be available on all carriers. The LBI services will not be available if your device or its location services are turned off.

Applying for Employment Online

When you apply for employment with PeopleScout or a PeopleScout Client, we may ask you to create a user profile. Your user profile will be used by PeopleScout to consider your qualifications for employment with PeopleScout or a PeopleScout Client. In addition, we will use your email address for the primary purpose of sending a confirmation that you have successfully completed your registration and to communicate with you about the employment application process. You may also consent to receive an email notification of future opportunities with PeopleScout by checking a preference box that appears when you create your user profile. If you change your mind and would like to stop receiving the emails, you may provide notice according to the instructions set forth below. You will create a username and password. You are responsible for the security of your password and login information, and we recommend that you not divulge your password to anyone. By providing any information to PeopleScout, you agree to take responsibility to ensure the confidentiality of your username and password. It is each user’s responsibility to keep his or her information accurate, up-to-date and current at all times. If your information is not accurate, up-to-date and current, we may not be able to process your requests for information or contacts or provide Service to you effectively. To update or correct your Personal Data or other profile information, you may log into your account on the Website and follow the instructions.

Our Promotional Updates and Communications

Where permitted in our legitimate interest or with your prior consent where required by law, we may use your Personal Data for marketing analysis and to provide you with promotional update communications and information about PeopleScout Services, opportunities with PeopleScout and/or PeopleScout Clients, and information about PeopleScout’s industry. You can object to further marketing at any time by updating your contact details in your account or by selecting the “unsubscribe” link at the end of all out marketing and promotional communications to you, or by sending us an email to marketing@peoplescout.com and privacy@trueblue.com.

Where We Store Your Information

The Personal Data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent data protection law. Where your Personal Data is transferred outside of the EEA, we will take steps reasonably necessary to ensure that your Personal Data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely in accordance with this Notice.

We may transfer your Personal Data to the following countries outside of the EEA: the USA, Australia, Canada and India.

Country Adequacy mechanism relied upon:

EU Standard contractual clauses for the transfer of personal data to third countries.

Our Use of Cookies and Other Tracking Technologies

We use “cookies”, clear gifs, log file information, and other tracking technologies (collectively, “Tracking Technologies”) to obtain certain information when your browser or mobile device
accesses our Website. For example, when you log in to our Website to apply for an employment opportunity, a session cookie is created while you are on the Website. This enables you to apply for multiple positions without having to log back into the system each time. If you do not wish to receive any Tracking Technologies, you should examine your browser settings and instructions, though we make no promise that they will be effective. This may mean you will not be able to take full advantage of the services provided on our Website.

We use Tracking Technologies to do a variety of things, including (without limitation) to: understand what web pages you have viewed, what links you click, the searches you conduct on the Website and how frequently specific pages are visited.

Most web browsers automatically accept cookies. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website or our Services. Similarly, you may be able to adjust settings on your mobile device to limit the Personal Data it stores, and these adjustments may affect your ability to access or use certain features of the website or our Services.

We may allow third parties to display advertisements or links on our Website or applications. These companies may use Tracking Technologies to collect information about users who view or click their advertisements or links. The collection and use of that information is subject to the third party’s privacy policy. We are not responsible for the data policies, content or security of other websites or applications that may be accessed by you through our services.

Your selection of a “Do Not Track” option provided by your browser may not have any effect on the Tracking Technologies or the automatic collection of analytics information. This may be for a number of reasons. For example, not all Tracking Technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a Tracking Technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

Information Security

The security of your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once it is received. We use appropriate physical, technical, administrative, and organizational security measures to protect your Personal Data from unauthorized processing.

However, the internet and mobile phones are not secure media and no system can be considered 100% secure. We do not guarantee Personal Data or Analytics Information is protected and we accept no liability for loss or exposure of user information in the event of a breach.

In the event a security breach should occur, we will endeavor to remedy the problem. By registering for our PeopleScout Services or by using the Website, you hereby affirmatively consent to receiving our notification regarding any breach or compromise, or suspected breach or compromise, of the security of your Personal Data, by email, telephone whether through voice or text messages, posting on our Website, or postal mail, as we deem appropriate, and as required by law.

It is your responsibility to keep your username, password and other account access information in a safe place and not to divulge it to anyone. Also, remember to log out of your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.

Retention and Deletion

PeopleScout may keep Personal Data and Analytics Information:

For as long as we have an ongoing legitimate business purpose for retaining such information;
for as long as we provide PeopleScout Services to you;
to comply with our legal obligations; and
to resolve disputes and enforce our agreements.

PeopleScout retains, deletes, and destroys Personal Data in compliance with our internal retention and deletions policies and schedules.

If your application for employment or engagement is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process to the extent necessary to enable PeopleScout to comply with any legal obligations or for the exercise or defence of legal claims (subject to any applicable legal or regulatory obligations to retain such information for a longer period).

Notice to California Residents - Your California Privacy Rights

California Civil Code Section 1798.83 permits users of our website who are California residents to request certain information regarding the disclosure, during the past year, of personal information for marketing purposes. To make such a request, please see our “Contact Us” section below.

Children

Our Services are only intended for use by persons who are 18 years of age or older. We do not knowingly collect Personal Data from persons under the age of 18. If we become aware or suspect that you are under the age of 18, any information you submit will be subject to our reasonable efforts to destroy such information, except as necessary for verifying your age or as required by law. No information should be submitted to PeopleScout by underage persons.

Changes in the Notice

PeopleScout may modify this Notice at any time, and any modified version is effective immediately upon posting. Should there be a material change this Notice, it will be applied to Personal Data and analytics information collected after the modified Notice is posted, unless you consent to the modified Notice in which case the changes shall apply to all previously and subsequently collected Personal Data and Analytics Information. We will notify you by means of a notice on this website prior to any material changes becoming effective. PeopleScout encourages you to review the Notice each time you visit our website.

Contact Information

Please feel free to contact us with any comments or questions regarding this Notice.

You may contact us via this Data Request form.

You may contact us at privacy@trueblue.com.

Alternatively, you may contact us at:

TrueBlue, Inc.
C/o PeopleScout, Inc.
1015 A Street
Tacoma, WA 98402 Attn: Privacy Group

If you are a resident of the EU, EEA, or Switzerland:

265 Tottenham Court Road, London, W1T 7RQ UK
020 7268 9156
Attn: Data Protection Officer

Or Richard.cook@peoplescout.co.uk.