California Privacy Policy

Last Updated: 28 June 2023

Michael Page International, Inc. (“Michael Page” or “Company”) takes your privacy seriously. We want you to know how we collect, use, disclose, and protect your personal data.

Assistance for the Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact Data Compliance datacompliance@michaelpage.us.com or our toll-free number 866-759-4213 for assistance.

This Privacy Policy explains:

  1. The categories of personal information we collect about you
  2. The categories of sources from which we collect your personal information
  3. The purposes for which we use your personal information
  4. How we may disclose your personal information 
  5. Your California privacy rights and how to exercise them
  6. Changes to this Privacy Policy

Scope:

This Privacy Policy only applies to the personal information of residents of the U.S. state of California, including (a) users of our websites (including but not limited to www.michaelpage.com), as they may be updated or moved over time, (the “Michael Page Site”), (b) applicants applying to work at Michael Page (“Michael Page Applicants”), (c) individuals seeking our assistance in finding a suitable job or contract at one of our clients (“Client Candidates”), and (d) contacts at our clients and business partners (“business contacts”). This Privacy Policy does not cover (i) Michael Page’s current or former California workers, e.g., employees and independent contractors, or (ii) their spouses, dependents, or beneficiaries because Michael Page has provided these individuals with a separate notice.    

For purposes of this Privacy Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident. Personal information does not include protected health information, as defined by HIPAA, or information subject to the Fair Credit Reporting Act.

1. The Categories of Personal Information We Collect About You

A. Website Users

  • Identifiers, for example: for example: name, e-mail address, and telephone number if you fill out a contact form.
  • Internet, or other electronic network activity information, for example: search history on our website, and interactions with Michael Page’s Internet website.
  • Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the web message.

B. Michael Page Applicants and Client Candidates

  • Identifiers, for example: name, e-mail address, and telephone number.
  • Internet, or other electronic network activity information, for example: search history on our website, interactions with Michael Page’s Internet website, and publicly available social media activity.
  • Professional or employment-related information, for example: qualifications, employment history, business contact information, title, educational institutions attended, degrees and certifications, licenses, work experience and previous employers, and professional memberships and affiliations.
  • Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the call or text (SMS or MMS) message and phone numbers.
  • Non-public educational information, for example: academic transcripts.
  • Sensory or Surveillance Data, for example: voice-mails, audio/visual recordings of interviews, and footage from video surveillance cameras. 
  • § 1798.80: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories in this section, such as a photograph.  
  • Other details, for example, hobbies and leisure activities or membership in voluntary/charitable/public organizations, for example, as stated on the Applicant’s resume.
  • Characteristics of Protected Classifications Under California or Federal Law, collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting and related purposes.

C. Business Contacts

Michael Page collects the categories of personal information listed in Section 1.A above, excluding the following categories: (a) Non-Public educational information; (b) § 1798.80; (c) Inferences; (d) Characteristics of Protected Classifications Under California or Federal Law; (e) Biometric information; (f) Geolocation data; and (g) Sensitive personal information.

Note on Sensitive Personal Information: Michael Page only uses sensitive personal information as necessary to perform the services the average person would reasonably expect when requesting those goods or services, to detect security incidents, to maintain the quality of our services, or for other purposes not granted the right to opt out under the California Privacy Rights Act.  Company does not infer characteristics from sensitive personal information

Do We Use Cookies?

Yes. Cookies are small files that the Site or our service provider transfers to your computer’s hard drive through your Web browser that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly. 

Google Analytics

We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our Site visitors.  These cookies collect data tied to a user’s IP address, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site.  Based on this information, Google Analytics compiles aggregate data about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future.  For more information on Google Analytics, visit https://support.google.com/analytics. 

Tracking

Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including the Michael Page Site, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.We may track your online activities over time and across third-party websites or online services. For example, we might use cookies to help us determine what links or advertisers brought you to the Michael Page Site. We then track your activities on the Michael Page Site. 2. The Categories of Sources From Which We Collect Your Personal Information

  • You, for example, when you register with our Site, fill out your job application or other forms you complete for us, and any information you provide us during the course of your relationship with us.
  • Service providers and vendors, for example, analytics providers, IT, and system administration services.
  • Affiliated companies, for example, so that we can assist other companies in the Michael Page family of companies in providing you with services.
  • Automated technologies, for example, browsing activity collected by automated technologies on the Site.
  • Third parties, for example, job references, personal or professional referrals through our network, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Public sources, for example, public databases and publicly available social media such as LinkedIn.
  • Surveillance/recording technologies installed by Michael Page, for example video surveillance in common areas of Michael Page facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
  • Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.
  • Acquired company, if Michael Page acquired another entity, Michael Page might collect personal information from that entity.

Note for Michael Page Applicants and Client Candidates: This Privacy Policy does not cover background screening conducted by third-party background check vendors subject to the federal Fair Credit Reporting Act.  Michael Page provides separate notices for such screening.

3. The Purposes For Which We Use Your Personal Information

A.  All California Residents

  • Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.
  • Providing information on using and displaying Company’s services.
  • Auditing related to a current interaction with the individual and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with the law.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use.
  • Performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising or marketing services, and providing analytic services.
  • Informing you of any changes to the services, your account (if applicable), this Privacy Policy, or any other policies or terms in relation thereto.
  • Protecting the rights, property, or safety of Michael Page, you, or others.
  • Exercising Michael Page’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
  • Ensuring compliance with applicable laws and regulatory obligations.
  • Conducting internal audits and investigations.

B.  Client Candidates 

The purposes listed in Section 3(A) above as well as:

  • Identifying potential job opportunities and facilitating job placement.
  • Matching your coded details with job vacancies, to assist us in finding you the position that most suits you.
  • Keeping you informed of Michael Page services, news, and wider developments in your chosen field.
  • For email marketing.
  • Compiling salary and other surveys of our candidates.
  • Identifying potential job opportunities for candidates and facilitating job placement.
  • Conducting background checks including criminal, credit and education as required by law.
  • For product and services training, for example, by providing training and information on using, servicing, selling, and displaying Michael Page’s services.
  • For communications about promotions, for example, by communicating about special events, sweepstakes, promotions, and surveys.
  • With the Client Candidate’s permission, we retain qualifications and employment history to ensure that we continue to offer suitable opportunities.

C. Michael Page Applicants

The purposes listed in Section 3(A) above as well as:

  • Conducting background checks including criminal, credit and education as required by law.
  • Evaluating applicants’ qualifications or suitability for employment with Michael Page.
  • For identification purposes.
  • For diversity and inclusion purposes.
  • Creating a talent pool for future job openings.
  • For recordkeeping purposes.
  • Demonstrating applicants’ agreement to, or acceptance of, documents presented to them, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter.
  • Evaluating and improving the recruiting process.
  • Promoting Michael Page as a place to work.

D. Business Contacts

The purposes listed in Section 3(A) above as well as: 

  • Fulfilling your recruitment needs.
  • Advertising and marketing.
  • Providing resources and support like expert management advice, events, and webinars.

Incidental Purposes: Any incident purposes related to, or in connection with, the above.

4.  How We May Disclose Your Personal Information 

Michael Page discloses personal information as necessary for the purposes described in Section 3 above to the following categories of external recipients:

  • Clients and potential clients: Michael Page discloses personal information of Client Candidates seeking Company’s assistance in finding a suitable job or contract with its clients and potential clients.
  • Service providers and contractors: Michael Page discloses your personal information to service providers and contractors for the purposes above to assist us in meeting our business needs and contractual and legal obligations.
    • Service providers and contractors include auditors, administrative service providers, law firms, and any other entity providing services to Michael Page.
  • Affiliated companies: Other companies within the Michael Page family, for example, to provide you with our services.
  • Government or administrative agencies: For example, Michael Page may report unlawful activity to law enforcement.  
  • Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
  • Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Michael Page, our users, or others.

We do not sell your personal information or disclose it to third parties for cross-context behavioral advertising (“sharing”). In addition, we have no actual knowledge that we sell the personal information of children under 16 or disclose it to third parties for cross-context behavioral advertising.

Aggregated and Deidentified Information

We may aggregate and/or deidentify information, use it internally, and disclose to third parties.  Neither Aggregated Information nor Deidentified Information (defined below) is personal information.

  • “Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.  
  • “Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be data point that an unidentified visitor first entered the Site through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.  We prohibit vendors, by contract, from attempting to reidentify our Deidentified Information. 

How Long We Keep Your Personal Information

For Michael Page Applicants:

If Michael Page hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes.  Michael Page will retain this application information for the entire duration of your employment relationship with Michael Page and for as long thereafter as permitted or required by applicable law.  Michael Page makes its document retention schedule available to employees for review.

Michael Page will retain information of Michael Page Applicants who are not hired for four (4) years after the record is collected.  These records will be retained for our internal recordkeeping and reporting purposes in compliance with California Government Code § 12946.  During that time, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

For All Other California Residents:

Michael Page retains your personal information for the duration of Company’s relationship with you.  Michael Page will retain personal information longer as necessary to comply with legal, administrative, or procedural requirements, for example, a litigation hold. 

5. Your California Privacy Rights and How To Exercise Them

Your California Privacy Rights: 

Subject to applicable law, California residents have the following rights:

  • Right to Know: California residents have the right to submit a verifiable request to know the specific pieces of personal information obtained from the resident and for information about the Company’s collection, use, and disclosure of the resident’s personal information. Please note that the CPRA’s right to know does not grant a right to the whole of any document that contains personal information, but only to “specific pieces” of personal information.  Moreover, California residents generally just have a right to know categories, for example, categories of third parties to which personal information is disclosed, but not the individual third parties.
  • Right To Delete: California residents have the right to submit a verifiable request for deletion of their personal information that they provided to Michael Page.
  • Right to Correct: California residents have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Michael Page, taking into account the nature of the personal information and the purposes of processing the personal information.

How to Exercise Your Rights:

Michael Page will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California residents can exercise their rights to know, delete, and correct in the following ways:

How We Will Verify Your Request:

The processes that we follow to verify your identity when you make a request to know or a request to delete are described below.  The relevant process depends on how and why the request is submitted.

Requests Using An Existing Email Account 

If you created a password-protected email account or registered on our database before the date of your request, we will rely on this account as verification of your identity.  We will ask that you re-authenticate your account via an automated email and will only disclose your personal information (in response to a request to know) or delete your personal information (in response to a request to delete) once the above steps have been completed.

Please note that you are responsible for protecting the security of your email account.  If we suspect fraudulent or malicious activity we will be unable to process your request until further verification checks have been made.

Requests Other Than Through A Password-Protected Account: 

We will match at least three data points that you provide with your request to know, against information we already hold about you on our systems and that we have determined to be reliable for purposes of verifying your identity. 

We have implemented the following additional procedures when verifying the identity of requestors:

  1. If we are unable to complete the above verifications, we may ask you for additional documentation.  All additional information will be permanently deleted after we have completed the verification process and will not be used for any other purpose.
  2. If we cannot verify your identity to a satisfactory level, we will provide you with a prompt decision and explanation.

Authorized Agents

You may designate an authorized agent to exercise your right to know or your right to delete by submitting to us a completed “Authorized Agent Designation” form.  You can obtain the designation form by contacting us at datacompliance@michaelpage.us.com.

If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit a document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you to follow the applicable process described above for verifying your identity.

Michael Page’s Non-Discrimination Policy

California residents have the right not to be subject to discriminatory treatment by Michael Page for exercising their privacy rights under the California Privacy Rights Act, and Michael Page will not discriminate on that basis. However, Michael Page may charge a California resident a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the California resident by the resident’s personal information. If Michael Page does so, it will provide residents with any legally required notice.

Changes To This Privacy Policy

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above.  If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

For More Information

For questions or concerns about Michael Page’s privacy policies and practices, please contact us at DataCompliance@michaelpage.us.com.