Indeed Inc. Liable for Agent Onward Transfer Violations

The updated terms authorize Indeed to process personal data for a broader range of purposes, including fraud, abuse, platform-security threats, and risks to users or the public. The policy now explicitly states that Indeed may share information with law enforcement, regulators, and government authorities where lawful and appropriate, including in cases where sharing is voluntary rather than in response to compulsory legal process. For job seekers, device information is now included when applications are transferred to employers' systems, such as applicant tracking systems or scheduling platforms.

The updated policy explicitly includes phone number as a type of device information that Indeed collects. Previously, the policy described device information as limited to IP address, device ID, and user agent. Additionally, the policy now states that Indeed relies on legitimate interests not only for keeping sites safe and secure, but also for 'improving our Sites and services', which broadens the stated basis for processing personal data. These changes formalize expanded data collection categories and processing justifications under the same legal framework.