Indeed Remains Liable for Agent Onward Transfer Violations

The updated policy expands the purposes for which Indeed processes personal data to include fraud, abuse, platform-security threats, and risks to users or the public, beyond the prior focus on illegal activities. The revised terms now explicitly authorize sharing such information with law enforcement, regulators, and government authorities on a voluntary basis where lawful and appropriate. For job seekers, the policy now specifies that device information will be included when sharing application and candidate data with employers' Applicant Tracking Systems and scheduling platforms. These changes broaden the categories of data that may be processed and disclosed without requiring affirmative user consent for each disclosure.

The updated policy now explicitly states that phone numbers are collected as part of device information, in addition to IP addresses and user agent data. The legal basis for collecting and processing user data was also expanded to include improving Indeed's sites and services, beyond the prior focus on site security and service validity. These changes broaden the scope of personal information collected and the purposes for which Indeed may use that information under its stated legitimate interests framework.