ASGN Incorporated (“the Company”, “we”, “our” or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how the Company may collect, use, disclose, and safeguard personal information that we may collect about you through our websites, and via offline means such as during interactions with our corporate suppliers and customers, via trade shows or other offline interactions, where applicable. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get exercise your rights and get answers to your questions. Our privacy practices with respect to personal information about our employees and contractors, past and present, are addressed through other internal company policies and procedures, and are outside the scope of this Policy.
You can access specific topics in this Policy by relevant information below:
- Information We Collect About You
- How We Collect Your Personal Information
- How We Use Your Personal Information
- Disclosures of Your Personal Information
- Data Security
- Retention Period
- Your Rights in Relation to Your Personal Information
- Other Important Information
1. Information We Collect About You
For the purposes of this Privacy Policy, “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, regardless of whether it is held in paper, electronic or any other format.
We collect, maintain, and use different types of personal information in the context of our relationship or potential relationship with you. The following provides examples of the type of information that we collect from you, and have collected in the preceding 12 months, and how we use the information.
| Context | Categories of Information | Primary Purpose for Collection and Use of Information |
|---|---|---|
| Commercial Information |
We collect basic identifying information such as your name, title, employer, and contact information such as your work and/or personal email address, and telephone numbers (including your mobile number). |
We have an interest in communicating with our clients concerning normal business administration such as projects, services, and billing. We have an interest in fulfilling our contract with you for the provision of services. |
| Cookies and First Party Tracking |
We use cookies and web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively “tracking technologies”) to monitor how you interact with our websites. This may include which links you click on, information that you type into our online forms, or identifying information about your device or browser. |
We have an interest in making our website operate efficiently, providing account related functionalities, understanding how you interact with our websites to better improve them, and maintaining security standards. We also have an interest in detecting and preventing fraud. |
| CCTV Recording and Photographs |
Your image which may be recorded on CCTV or by our sign in system when you visit our premises. |
We have a legitimate interest in protecting our customers, our premises, assets, and business partners from crime. We operate CCTV security and sign in systems in a number of our premises and parking lots which record images for security. |
| Email Interconnectivity |
If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages. |
We have an interest in understanding how you interact with our communications to you. |
| Feedback/ Support | If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. |
We have an interest in receiving, and acting upon, your feedback or issues. |
| Mailing List |
When you sign up for one of our mailing lists we collect your basic identifying and contact information such as your name, email address or postal address. |
We disclose information about our services with individuals who consent to receive such information. We have an interest in disclosing information about our services. |
| Mobile Devices |
We may collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites. |
We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. |
| Supplier Relationship Management |
We collect certain contact and related business information (name, email address, professional contact information) when you or your organization provides us with certain products or services. In some instances, we may collect certain background or screening information to the extent needed and in accordance with applicable law. |
We have an interest in administering our relationship with our suppliers and performing our contract with your organization. We also use such information to administer and maintain our relationship with your organization. |
| Web Logs |
We collect information, including your browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, and/or a date/time stamp for visitors. |
We have an interest in monitoring our networks and the visitors to our websites. |
2. How We Collect Your Personal Information
We collect your personal information in the following ways, pursuant to applicable law:
- Directly From You, when you apply for our services, attend trade shows and industry events, engage with our websites, transact business with us, register for an account, contact us, respond to a survey, sign up to receive emails, and/or postal mailings. If you provide us a mobile phone number, you agree to receive text messages from the Company. Text messages may be sent to notify you of a position or keep you updated on activities relevant to your application process, which may include reminders.
- Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our websites, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools.
- Through On Premise and Other Offline Technologies. We also use Closed Circuit Television or CCTV in our locations for safety, security, fraud, loss prevention, and operational purposes.
- From Third Parties, including business partners, our affiliates, data analytics providers, third parties that we have partnered with for marketing or other purposes, or other publicly available sources.
3. How We Use Your Personal Information
In addition to the purposes and uses described above, we use your personal information for the following purposes:
- To provide services to your business or employer;
- To respond to inquiries related to support, employment opportunities, or other requests;
- To send marketing and promotional materials, including information relating to our services;
- To comply with laws or regulations to which the Company is subject;
- To comply with our contractual obligations;
- To conduct research and analytics related to our websites and services, including combining any or all of the information that we collect or obtain;
- To detect and prevent fraud or crime;
- To enforce, exercise, or defend legal claims;
- To detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of us and our customers, employees, or others; and
- For internal administrative purposes, as well as to manage our relationships
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. Our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business. Note that this Privacy Policy may be updated to notify you of additional purposes for which we process your personal information.
4. Disclosures of Your Personal Information
In addition to the specific situations discussed elsewhere in this policy, we share your personal information in the following situations:
- Affiliates. We may disclose information to our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) in the course of our normal business operations.
- Business Transactions. If another company acquires, or plans to acquire, any part of our company, business, or our assets, or similar corporate restructuring activities, we will also disclose information to that company, including at the negotiation stage.
- Legal or Regulatory Requests and Investigations. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or regulations. We may also need to disclose your personal information to tax authorities, courts, regulators, the police and other governmental authorities where we are required or permitted to do so by law.
- Other Disclosures with Your Consent. We may ask to disclose your information to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
Protection of the Company or Others. We may disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies. - Third-Party Service Providers. We may disclose your information to service providers. Among other things, service providers may help us to administer our website, provide technical support, and assist in the fulfillment of services.
- De-identified Personal Information. We may disclose or use aggregated or de-identified data for any lawful purpose. De identified information is generally not considered to be Personal Information under applicable laws
5. Data Security
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we maintain reasonable physical, technical and procedural safeguards that are designed to protect your personal information against unauthorized access use, or disclosure we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites may permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account by using one of the methods listed below under “Contact Information.”
6. Retention Period
We retain information about you and your relationship with us for as long as is needed to fulfil our legitimate business purposes outlined in this Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations.
7. Your Rights in Relation to Your Personal Information
You can make the following choices regarding your personal information:
- Notification of Employment Opportunities. You may choose to provide us with your email address for the purpose of allowing us to send employment or candidate opportunities to you. You can stop receiving these emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive these emails, we may still send you service-related communications.
- Request access to your personal information. You have the right to request access to personal information we hold about you. Specifically, you have the right to request access to information about the categories of personal information concerned and categories of recipients to whom the personal information has been or will be disclosed, and the sources from which we receive that personal information among other information. You generally have the right to receive this personal information in a structured, commonly used, and machine-readable format so you can transmit this personal information to another entity.
- Request deletion of your personal information. You may request that we delete your personal information. There may be instances where applicable law or regulatory requirements allow or require us to refuse a deletion request. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
- Online Tracking. Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. Not all browsers offer a DNT option and there is currently no industry consensus for how to recognize or respond to a DNT signal. For these reasons, we do not currently respond to DNT signals. We will endeavor to recognize commercially recognized opt out signals in accordance with legal requirements (e.g., Global Privacy Control). Recognition of this signal will only take place with respect to the device and/or browser that communicates the signal.
- Opt-Out of the Sale or Sharing of Personal Information. Subject to certain exceptions, California residents have the right to opt out of the "sale"/”sharing” of their personal information. It may be considered a “sale”/”sharing” of personal information under California law if we were to use services that help deliver ads to you or transfer personal information to business partners for their use. Making personal information (such as online/device identifiers, browsing activity, or geolocation) available to these third parties may be considered a “share” under California law. At this time we do not make your personal information available to third parties for these uses, but if we do in the future we will update this section and you may opt out of such sharing by submitting your request online here.
- Automated Processing. We do not use any technology that makes a significant decision based solely on automated processing (i.e., without human intervention). In the event we begin to use such technology, you have the right to object to that automated processing unless that decision is required or authorized by law.
- Right of Non-Discrimination/Retaliation. We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.
- Right to Restrict Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). You have the right to request the restriction of processing of your sensitive personal information. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those described in this Policy and these uses cannot be limited under applicable law.
- Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.
A person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.
Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Call us at 800-536-1390; or submit your request online.
8. Other Important Information
The following additional information relates to our privacy practices:
- Changes To This Privacy Policy: We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
- Accessibility ASGN is dedicated to providing an equivalent digital experience for our guests, regardless of physical or cognitive ability. This Privacy Policy is accessible to all – including those who rely on assistive technology.
- Minors: We will not knowingly collect any personally identifiable information from children under the age of 13 and our websites and our services are not directed to children under the age of 13. If a child under 13 submits personal information to us and we learn that the information is from a child under 13, we will attempt to delete the information as soon as possible. In addition, we do not knowingly sell the personal information of minors under the age of 16.
- Information for California Residents: If you would like more information concerning the categories of personal information (if any) we disclose to third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the "Contact Information" section below.
Contact Information: If you have any questions about this Privacy Policy, please us contact at myprivacy@asgn.com.
Last Revised January 1, 2023