What personal data we collect

The reason we use your personal data

1

Information you provide to us as part of the registration process and our relationship with you when you apply for employment with us orengage us to provide recruitment or job-matching services whether provided online, in-person, or by telephone, including: 

• Identifiers: Name and contact information – including: postal address, e-mail address, telephone number, date of birth, and other similar contact data.
  
• Education, work history, and qualifications – including your education history, employment history, work-related skills and experience, professional credentials or licenses, membership in professional organizations, career interests, preferences, qualifications, information provided by references, and other information provided on your résumé or Curriculum Vitae (CV).

• Financial Information - including information related to your bank account, tax status, benefits or payroll records. 

• Characteristics of Protected Classifications  – including your citizenship and work authorization status, and contents of any other identification provided to Kelly for application or employment purposes.
• Sensitive Personal Information – including your employee identification or social security number and/or driver’s license, passport, or State ID number and contents.
• Job-related social media data – including  collecting your information from and related to publicly published profiles you’ve created on job-related social media platforms and job boards (such as LinkedIn, Monster, or Indeed)
• Performance and Employment data – including information contained in your personnel file with Kelly, performance reviews, assessments, and disciplinary action. For additional detail on employee privacy, internal employees should review relevant internal policies.

We use this personal data: 

• to create, manage, and administer the individual's relationship with us;
• to assess an individual's suitability for employment and employ individuals;
• to match candidates with potential positions;
• to offer candidates placement at our customers;
• to refer an individual for employment to one of our customers;
• to provide general work-seeking services to individuals;
• to meet our obligations when acting as an employer in connection with the contract of employment and other obligations which apply to us under applicable employment laws;
• to manage the employment relationship with an individual, including for human resources management (for example career development, training, talent management, performance management, appraisals, and disciplinary and grievance management);
• to detect or prevent any inappropriate behavior or breach of our policies, including protecting our intellectual property, confidential information, and assets;
• for making contact in an emergency;
• for ensuring that our (or any of our group companies) systems are used primarily for business purposes, have sufficient capacity for the needs of the business, and are protected against cybersecurity threats such as malware;
• to meet our obligations to an individual in respect of our contract with the individual when we act as an employer, employment agency, recruiter, hirer, or outsourcing or consulting agency;
• to contact individuals via regular mail, e-mail, phone, text messages, and online communication platforms about our company or job openings that match the individual's stated preferences, qualifications, and/or profile; these communications will only come directly from Kelly Services (or agents working on behalf of Kelly). At all times, individuals may opt out of receiving these communications; for details see the Your Rights and Choices section below);
• for the purposes of any potential and/ or actual litigation or investigations concerning us or any group company or its officers; and
• to personalize and deliver content about our services to individuals. For example, where individuals share geolocation data with us, this will allow the individual to search for jobs or create job alerts within that geographic area.
• in the United States, Canada, and Puerto Rico, for certain positions, to deliver automated feedback on positions for which you may be qualified for or may not meet job requirements, based on years of experience, certifications, and other job requirements. 

• Necessary for establishment or performance of a contract (employment);
• Necessary to comply with legal obligations as an employer to determine authorization for employment, provide benefits, and pay wages;
• Necessary for exercise of our legitimate interests as an employer to identify and provide job opportunities for candidates and employees, determine suitability for job opportunities, communicate with individuals regarding potential job opportunities, establish and maintain candidate and employee records, promote an inclusive work environment, manage an individual’s candidate or employment relationship, and prevent fraud.
• Necessary to protect vital interests in event of an emergency.

2

Information that we receive from our customers and other third parties about their employees and other personnel that we require for the purposes of providing staffing consultancy and outsourcing services including: 

• Identifiers: Name and contact information – including: postal address, e-mail address, telephone number, date of birth, and other similar contact data
  
  
• Education, work history, and qualifications – including your education history, employment history, work-related skills and experience, professional credentials or licenses, membership in professional organizations, career interests, preferences, qualifications, information provided by references, and other information provided on your résumé or Curriculum Vitae (CV). 
• Financial Information including information related to your bank account, tax status, or payroll records.  

• Characteristics of Protected Classifications – including your citizenship and work authorization status, and contents of any other identification provided to Kelly for application or employment purposes.
• Sensitive Personal Information  – including your employee identification or social security number and/or driver’s license, passport, or State ID number and contents. 

• Performance and Employment data – including information contained in your personnel file with Kelly, performance reviews, assessments, and disciplinary action.

We use this personal data:

• to provide staffing consultancy, outsourcing, and vendor management services;

• for staff administration and operational purposes (for example, in relation to absences, pay, benefits, compensation, stock administration, business travel, maintaining employee directories, enabling access to our systems and resources, managing authorization controls, ensuring the security of our systems and resources, management forecasts, and planning changes in our group structure); 

• to manage the employment or outsourcing relationship, such as responding to inquiries, providing human resource services, processing and administering payments and payroll, administering benefits, providing counseling, training, or discipline, complying with health, safety, and internal policies, corporate management, career and performance monitoring, and employment contract administration 

• to provide, improve, or develop services we provide to our customers, suppliers, or service providers or to perform essential business operations. This includes performing data analysis, research, and studies to assess the candidate, employee, and contractor population for staffing and outsourcing services. This also includes analyzing trends in hiring and placement opportunities, evaluating workforce trends related to requested and available skills and experience, researching, implementing, and marketing business opportunities, analyzing employee distribution, succession planning, and corporate organization. These tasks are necessary to recruit, match, and present potential placement opportunities for individuals in our staffing and outsourcing programs; 

• to detect or prevent any inappropriate behavior or breach of our policies including protecting our intellectual property, confidential information, and assets; 

• for ensuring that our (or any of our group companies) systems are used primarily for business purposes, have sufficient capacity for the needs of the business, are protected against cybersecurity threats such as malware; and 

• for the purposes of any potential and/ or actual litigation or investigations concerning us or any group company or its officers.

• Necessary for exercise of our legitimate interests as a provider of staffing, outsourcing and consulting services to identify and provide job opportunities for candidates and employees, determine suitability for job opportunities, communicate with individuals regarding potential job opportunities, establish and maintain candidate and employee records, promote an inclusive work environment, manage an individual’s candidate or employment relationship, and prevent fraud. 

3

Sensitive Personal Information and Biometric Information: Information collected about you which falls within "special categories of personal data" including: 

• Screening data – including drug, alcohol, and criminal background checks.
• Financial and benefits data – including your national or tax identification number, social security number, financial or bank account information, tax-related information, next-of-kin or emergency contact information, benefits selections potentially including health insurance,  retirement planning information, and disability and health-related information, and health information, including that related to a work-related claim (e.g. Workers’ Compensation Claim).
• Information relating to leaves of absence - including sickness absence or family related leaves.
• Information about your physical or mental health, condition, or disability status.
• Additional demographic information – including, your gender, race, ethnicity, disability, veteran information, ideological views or activities, or membership in trade unions.
• Biometric Data – including utilizing fingerprint identification.

We use this personal data as outlined below: 

• In some jurisdictions, we must process this personal data in order to comply with statutes, rules, and regulations pertaining to equal employment opportunities or to assist Kelly Services in compiling data for its equal opportunities practices and reporting, we may also ask you to provide additional information. The provision of this type of information will be voluntary, unless it is required by law, and failure to provide this information will not hinder your employment or project opportunities.
• We collect and use Screening Data when consistent with a legal basis and only as authorized under applicable law.
• We collect and use financial and benefits data to administer payments to you, provide employment-related health and retirement services, and other benefits applicable to your employment.
• We collect and use biometric data in order to limit access to certain secure locations.
• We use information relating to leaves of absence to comply with employment, social security, social protection and other laws, and to record and administer sickness and maternity leave.
• We use information about your physical or mental health to ensure your health and safety in the workplace and to assess your fitness to work subject to appropriate confidentiality safeguards and to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

• Necessary for establishment or performance of a contract (employment); 
• Necessary to comply with legal obligations as an employer to determine authorization for employment, provide benefits, and pay wages 
• Necessary for exercise of our legitimate interests as an employer to identify and provide job opportunities for candidates and employees, determine suitability for job opportunities, communicate with individuals regarding potential job opportunities, establish and maintain candidate and employee records, promote an inclusive work environment, manage an individual’s candidate or employment relationship, and prevent fraud. 

4

Identifiers: Information that we collect from individuals representing organizations, including:

• contact details of individuals working for our customers, service providers, and suppliers.
• contact details of individuals who attend our sponsored events, conferences, and webinars.
• other personal information regarding such individuals.

We use this information to:

• provide and manage staffing placement, consultancy, outsourcing, and vendor management services; 

• develop and maintain staffing and outsourcing relationships with our customers, suppliers, and service providers. We use the information, including delivering event and marketing communications, through e-mail, telephone, text messaging, direct mail, and online communication platforms. These notifications will provide instructions on how to opt out of receiving similar e-mails or communications from the service; and 
• improve our services and develop new services based on the preferences and behaviors of these individuals. 

• Necessary for performance of a contract with the organization; 
• Necessary for exercise of our legitimate interests as a provider of staffing, outsourcing, and sourcing services to provide services to our customers and potential customers, identify potential customers, and perform marketing activities to promote our services. 

5

Electronic Network Activity Information: Information we collect through your use of our website, including: 

• Website data – We collect User ID, log-in credentials, password, and/or PIN.
• Location data – We collect data about your location, such as Global Navigation Satellite System (GNSS) data (e.g., GPS), data identifying nearby cellular towers and Wi-Fi hotspots.
• IT Usage data – We collect information about your use of our IT equipment including monitoring compliance with applicable policies. 
• Cookies and similar data – As further described in our Cookie Policy, we use cookies, web beacons, and other similar technologies to recognize and personalize your online experience with Kelly. 

We use this information to:

• identify issues with the website or application and user's experience of the website or application;
• manage and administer our IT systems and devices; and
• monitor the way our website is used (including locations it is accessed from, devices it is accessed from, understanding peak usage times, and analyzing what functionality and information is most and least accessed). 
• Monitor threats to our IT system, identifying and fixing technical issues, and identifying and tackling cyber security risks.

Instead of having to type in your personal information, some of functionalities on our website may allow you to use third-party authentication tools such as Facebook, Twitter, and Google to populate certain fields. By authenticating through one of the social media options, you allow us to receive your personal and other information that is accessible through these tools. This information may be incorporated into your profile. For any such tool you choose to use, we encourage you to also review the tool provider’s privacy policy and any terms and conditions.

All of our IT systems are auditable and can be monitored, though we do not do this routinely. We are committed to respecting individual users’ reasonable expectations of privacy concerning the use of our IT systems and equipment.

• Necessary for performance of a contract; 
• Necessary to comply with a legal obligation; 
• Necessary for exercise of our legitimate interests to ensure a safe and secure our information technology systems and to make decisions to protect or systems and data. 

6

Information when you communicate with us whether in person, through our website or via e-mail, over the phone, through social media, or via any other medium, including:

• your contact details (which can include your e-mail address or social media account details, depending on how you choose to communicate with us)
• the details of your communications with us (including when you sent it, when we received it and where you sent it from (such as our website, post, telephone, e-mail, or social media))
• the details of our messages to you (including information that you may post on our social media platforms)

We use this information to:

• answer any issues or concerns;
• monitor communications for quality and training purposes;
• develop new services which is based on the information you provide;
• improve our services based on the information and feedback you provide and the information and feedback provided by others; 
• personalize our service to you to take account of the information and feedback you have provided; and
• make necessary disclosures in response requests which we are legally required to comply with, to law enforcement or regulatory authority, body or agency, or in the defense of legal claims.

We may use personal information to permit you to participate in live social media feeds. If you choose to participate, your public username may be displayed on the sites along with your post, including, but not limited to, comments, images, and video. We may provide you with access to third-party functionality that allows you to post content to your social media account(s). Any information that you provide through use of this functionality is governed by the applicable third party's privacy policy, and not by this Privacy Statement.

• Necessary for performance of a contract; 
• Necessary to comply with a legal obligation (employment laws); 
• Necessary for exercise of our legitimate interests as an employer to interact with you. 

7

Screening Information: Information that we collect from third party partners, our customers, and other Kelly companies which includes:

• Credit reference agencies
• Background screening companies
• Identity verification companies
• Other entities in our group

We use this information to:

• ensure that individual are genuine and to verify the information provided to guard against fraud and other criminal activities;
• provide, manage, and administer our services to individuals and our customers;
• manage and administer our IT systems;
• personalize our service to you by complementing your behaviors and preferences;
• perform statistical analysis and research into the individuals using our services so that we can better understand our users and develop and improve our services to meet the needs and preferences of our users and our customers; and
• combine this information with other types of information mentioned above to create holistic profiles of our customers which allows us to make our services more personal and tailored to each customer's preferences and habits.

• Necessary for establishment or performance of a contract (employment); 
• Necessary to comply with legal obligations as an employer; 
• Necessary for exercise of our legitimate interests as an employer to determine suitability for employment, prevent fraud, and manage secure access to or information systems.  

8

Information that we collect incidentally from other sources or public sources, including:

• information available in the media;
• information presented on our social media or wider social media platforms including Facebook, Twitter, and LinkedIn;
• information collected by security systems

We use this information to:

• maintain market awareness;
• build and maintain social media presence and branding; and
• provide security to our premises.

• Necessary for exercise of our legitimate interests as an employer to promote our business objectives, advance our brand, and protect the safety and welfare of our employees. 

9

Information that we collect from publicly available social media profiles and employment related websites including: 

• Name, education, job title, employment details 
• Inferences: Including inferences drawn from other personal information such as work-related skills or experience. 

We use this information to: 

• to assess an individual’s suitability for employment and to employ individuals; 
• to match candidates with potential positions; 
• to offer candidates placement at our customers; 
• to refer an individual for employment to one of our customers 
• to contact individuals via regular mail, e-mail, phone, text messages, and online communication platforms about our company or job openings that match the individual’s stated preferences, qualifications, and/or profile; these communications will only come directly from Kelly Services (or agents working on behalf of Kelly). At all times, individuals may opt out of receiving these communications; for details see the Your Rights and Choices section below.

• Necessary for establishment or performance of a contract (employment); 
• Necessary to comply with legal obligations as an employer; 
• Necessary for exercise of our legitimate interests as an employer to identify and provide job opportunities for candidates and employees, determine suitability for job opportunities, and communicate with individuals regarding potential job opportunities.