Privacy Policy

Introduction to PageGroup and how we handle your personal information

Michael Page (Shanghai) Recruitment Co., Limited (“PageGroup Shanghai”) is a specialist recruitment company operating under the brands Michael Page, Page Executive and Page Outsourcing. We are committed to protecting your privacy. Whether PageGroup Shanghai will become your data controller entity will depend on the type of services we provide to you, as detailed below. If you would like to access the full list of PageGroup entities, click here (the “PageGroup”).

We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or that we collect through various channels (including our website, through correspondence (including e-mail), conversations or meetings with our consultants, or through all of our offices worldwide), is used only for the purposes set forth in this Privacy Policy. Please also submit your information to us in accordance with our resume upload rules. If you would like to access the Resume Upload Rules, please click here ("Resume Upload Rules").

Through this Privacy Policy, we aim to inform you about the types of personal information we collect, the purposes for which we use the data and the way in which we process it. And, we will also comply with our obligations under relevant laws and regulations that may apply.

The Scope

Protecting your personal information is our top priority. This Privacy Policy describes how we handle and protect the following personal information:

• Candidates registered with us as a result of applying for open positions that we manage for other employers or for positions within us;
• Candidates who register with us through our website, job boards, social media sites or other sources;
• Potential candidates;
• Employees of potential customers; and
• Business contact information for our customers and third-party service providers.
  (hereinafter referred to as "you" or "your" or "user")

This Privacy Policy also informs you of your rights (including but not limited to your rights if you object to our processing of your information). If you would like to contact us, please see the Contact Us section of this policy.

I. Personal Information We Collect

We collect and use your personal information in accordance with the principles of legitimacy, minimum necessity, and transparency, and for the purposes described in this policy.We do not collect personal information that is not relevant to the provision of our services, and we will not deny you access to the basic functionality of our website services because you do not consent to the collection of non-essential personal information.If we use your personal information for other purposes not set out in this policy, or collect or use your personal information for other specific purposes, we will inform you in a reasonable manner and obtain your consent again before collection or use.

1. Candidates
1.1 Registration

When you register with us as a candidate and we provide recruitment services to you, we will process your personal information, including name, date of birth, contact number, email address, WeChat ID, city of residence, postal code, education background, major, skills, job level, title, industry field, functional field, current salary range, expected salary range, salary structure, job position (title), start date availability, willingness to consider non-permanent full-time employment, notice period for resignation, hobbies and interests, social account ID, internship experience, awards received, non-degree training courses, pet ownership status, other non-career related skills and qualifications, additional salary requirements.

1.2 Data from third parties

We will carry out surveys to third parties after explicitly obtaining your authorized consent, and if you agree to carry out surveys, you should ensure that the content of the information you provide about yourself is true and complete. The scope of the survey third party includes:

• Referrer--when you get or are about to get a job;
• Former employer -- to confirm date of employment;
• Educational institutions -- to check your qualifications;
• Credit reference agencies -- if we need to make the necessary inquiries about your financial situation;
• Open sources, such as social media sites, to enhance our understanding of relevant information about you, which will help us to find a more suitable position for you better;
• Clients to whom we have provided your job resume; and clients to whom your job application relates or who have provided feedback on your job resume during the job search process.

2. Potential candidates

We collect personal information about you, including your name and contact details and professional history from publicly available sources such as resume sites and social media sites, so that we can contact you in the future if we think you may be interested in our jobs and services, unless you explicitly object to the collection of your personal information if you are aware of it.In this case, PageGroup Shanghai will act as your data controller.

3. Employees of potential customers

We collect your contact information and data related to your function or position in order to establish a business relationship with your company. In this case, PageGroup Shanghai will act as your data controller.

4. Customer's business contact information

We collect personal information such as your name, job title and contact details. We also process information related to feedback you provide to us about our candidates. In this case PageGroup Shanghai will act as your data controller.

If you provide us with information about a candidate (for example, if you confirm that a candidate has worked with you or you have provided a reference), then we will obtain your details from that candidate and we will keep a record of the personal information you provide to us about that candidate.

We also process your personal data from the public domain, such as your personal data obtained through social networking sites, or your personal data obtained by us because you are acting as a delegate for one of our events, or your personal data obtained by a third party event organizer where they are permitted to share delegate details with us.

5. Business contact information for third-party service providers

We typically collect your name and contact information for the purpose of business contact with your entity. In this case, PageGroup Shanghai will act as your data controller.

6. Information collected through cookies and similar technologies

We collect personal information about you, such as your IP address and other data about your device, which we need to provide you with our online content. We also collect data about your participation in our website, opening emails or applications sent by us, such as the pages you view. If you contact us, we also collect information about your query. If you contact us, we may also collect information about your query. We use cookies and similar technologies to collect this data and our cookie policy will tell you more about this. In such cases, PageGroup Shanghai will act as your data controller, details of which can be found in the website's legal notice or in the list attached at the beginning of this privacy policy. 

II. How we use your personal information

In accordance with relevant laws and regulations, we process your personal information on the following legitimate grounds.

How we use your personal data

(a) Fulfillment of the contract - To fulfill our obligations under a contract we have entered into with you. For example, a service contract with a customer;our terms of service or other terms to which the candidate agrees;or, in the case of a prospective client or candidate, the steps necessary to enable the prospective client or candidate to enter into a contract with us.

(b) Compliance with legal obligation - We need to process your personal data in order to comply with our obligations under laws and regulations.

(c) Our or a third party's legitimate interests, including:

• Responding to your requests and inquiries (in which case we have a legitimate interest in maintaining ongoing and occasional communication with clients and candidates, which is an inaccessible part of any business relationship);
• Optimize the performance and user experience of our website;
• Contacting potential clients in order to establish a business relationship with them (in which case we have a legitimate interest in maintaining various forms of relationship with the company in which the contact person works);
• Inform you about our services, job opportunities, industry reports and recommendations, opinions, events, promotions and competitions (in which case we have a legitimate interest in introducing clients and candidates to similar services and products);and
• Provide surveys on satisfaction with our services.

(d) Based on your consent - In some cases, we will ask for your consent to process your personal information. For example, if you register an application for a job, we will provide you with a reminder of the possibility of applying for a similar job. If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact us, see the "Contact Us" section of this policy.

In addition, you have the right to unsubscribe from our marketing communications by using the unsubscribe method included in our marketing communications or by contacting us directly. We have also created a Marketing Preference Center where you can view and select your marketing preferences and opt out of receiving marketing promotions from us at any time.

1. Candidates

We use your personal information to:

• Provide you with services related to job searching;
• Communicating with you;
• Enables you to upload your resume and apply for jobs;
• Personalize your experience by creating a candidate profile;
• Enable us to monitor equality and diversity;
• Provide you with interview and salary advice; and
• Push marketing messages to you to inform you of job opportunities, industry reports and recommendations, opinions, promotions and contests, and other content based on your preferred choices;
• We also place targeted and relevant banner advertisements on our website and in your social networks to introduce you or candidates similar to you to job opportunities and content that we think you would be interested in. We target these advertisements based on your interactions with our website or email interactions, as well as your interactions with our consultants. Your interaction with our advertisements may be used to measure the effectiveness of our advertising campaigns and to improve our marketing strategies. This processing is carried out through cookies and, only with your prior consent, will we carry out the aforementioned activities.

2.Potential candidates and customers

We may use your personal data:

• Determine whether you are interested in our services and how we can help you;
• Contact you to find out if you are interested in our services.

3.Customer's business contact information

We may use your personal information to:

• Recruitment services for your company;
• Communicating with you;
• Getting your feedback on our services through customer satisfaction surveys to improve our services and develop new ones;
• Maintaining our business relationship with your company;
• Answering your inquiries when you contact us;
• Fulfillment of contractual obligations to your company;
• Establishing, exercising or defending legal rights and interests; and
• For marketing purposes.

4.Business contact information for suppliers

We use your personal information to:

• Communicating with you;
• Maintaining our business relationship with your company;
• Answering your inquiries when you contact us;
• Fulfillment of contractual obligations to your company;
• Establishing, exercising or defending legal rights and interests; and
• For marketing purposes.

III. Decision-making and analysis of information automation

We do not make decisions based on automated processing alone; Human intervention occurs before a decision is made. If you do not agree with our automated decision-making and analysis of information, please contact us, as described in the "Contact Us" section of this policy. We perform two types of analysis based on a candidate's personal information.

• JobMatch is a tool on our website for candidates to upload their resumes so that we can recommend compatible job opportunities. Of course, this profiling does not limit or exclude your access to other jobs and positions.
• Intelligent searches in our client database allow us to filter CVs when we receive many job applications and filter them by entering relevant keywords, e.g. by years of experience or field of practice.It then analyzes all resumes uploaded to it and provides a smaller range of candidates by matching keywords in their resumes and ranking candidates based on how well they match the position. As mentioned above, there is always a recruiter verifying the process, so the process is not a purely automated decision.

Please note that none of these profiling activities will have a significant legal or similar impact on the candidate, but if you would like to know more, please contact us, as described in the "Contact Us" section of this policy.

IV. With whom we share your personal information

In some cases, we will share your personal information with the following parties.

We perform two types of profiling based on candidate’s personal data:

1. Other companies in our group

PageGroup is a group that operates on a global basis. We may share or allow access to your personal information with other PageGroup entities.

The purpose of sharing your personal information within the PageGroup Group is:i) Centralized processing of some of the support necessary for us to provide our services, (e.g. IT, commercial and sales support), in which case the entity where the centralized processing takes place will act as a data processor to access and process your personal information and follow the instructions of your data controller;ii) global, regional management positions or senior executive positions, or the development of key accounts, which will require collaboration between different companies across the Group; and(iii) Management of positions that can be performed remotely. The legal basis for the application of these processing activities is the fulfillment of agreements with clients and candidates or the taking of steps necessary to facilitate the conclusion of agreements, and PageGroup's legitimate interest in utilizing internal resources to provide services.

Please note that if you re-register or otherwise establish a business relationship with us in a different country than the one in which you originally registered as a candidate with us, we will create a unique mark for you.A single token avoids duplication to improve the accuracy of personal information. For these purposes, the PageGroup companies involved will share your personal information as independent data controllers.

2.Third parties

• Conducting background checks;
• Conducting qualification checks;
• Conducting criminal record checks (if required);
• Verify the information you provide from third-party sources;
• Conducting psychological evaluations or skills tests;
• Hosting personal information for us;
• Provide us with professional advice;
• Provide us with data analysis;
• Testing and development work on our business technology systems;
• Administering surveys or competitions on our behalf;
• Assist us in communicating with you; and
• Providing research and mailing companies or other direct marketing services.

We require our third-party service providers in the relevant contracts to provide confidentiality and protection of data that meets the necessary standards of the relevant laws and regulations. If we need to transfer personal information outside mainland China, we will ensure that appropriate safeguards are in place.

3. Other disclosures

In addition, we may disclose your personal information for the following reasons:

• If we are legally required to do so;
• Disclosure to law enforcement agencies, regulatory bodies or other governmental authorities; and
• Disclosure to new business owners and their advisors in the event of a reorganization, merger, sale, joint venture, assignment or other transfer or disposition of all or a portion of our business.(If the foregoing occurs and any change in processing occurs involving disclosure of personal information, we will re-solicit authorized consent from you.)

Data protection laws may vary from country to country and in such cases we will take steps to ensure that the data we collect is processed in accordance with this policy and the requirements of Chinese law.Before providing your personal information outside of China, we will comply with the laws, administrative regulations and the provisions of the national Internet information authorities by carrying out a security assessment of data exit, certification of personal information protection by a professional organization, or signing a standard contract of data exit formulated by the Internet information authorities with the recipient of the data outside of China.We will require overseas data receivers to protect your personal information in accordance with security and confidentiality measures that are no less stringent than those required by Chinese law and fulfill the corresponding personal information protection obligations.

1. Cross-border principles for personal information
PageGroup Shanghai will strictly follow the principles of legality, legitimacy, necessity and good faith, strictly implement laws and regulations and the provisions of the relevant regulatory authorities, adopt methods that minimize the impact on the rights and interests of personal information to handle personal information, and strictly comply with the agreements and commitments of all parties to safeguard the legitimate rights and interests of the subject of personal information. When PageGroup Shanghai handles matters related to the cross-border flow of personal information, it will accurately and timely inform you of matters related to the exit of information in accordance with the requirements of the principles of openness and transparency, and safeguard your right to informed consent.

2. Exit of personal information

(1) Purpose of departure of personal information

PageGroup Shanghai is here to process your job applications, match you with jobs that match you, and refer you to PageGroup itself as well as to our clients around the world.

(2) Types of personal information for exit

Your current name, date of birth, contact phone number, email address, WeChat ID, city of residence, zip code, education, specialty, skills, grade, title, industry sector, functional area, current salary range, expected salary range, salary structure, job title (letterhead), availability, whether considering non-permanent fixed regular form of employment, notice period for separation.

(3) Offshore recipient and contact information

Offshore recipient:Michael Page International Recruitment Limited

Contact address:2nd Floor, 61 Aldwych, London,WC2B 4AE

(4) Exit Processing

Personal information collected and generated by PageGroup Shanghai in the People's Republic of China is stored in the People's Republic of China.PageGroup Shanghai will transmit the relevant personal information through the NextGen system to the offshore Customer Connect system for the offshore recipient to view and access.

(5) Manner of exercising rights

If you need to claim or exercise your rights related to your personal information from the overseas recipient, you may contact the overseas recipient directly or contact PageGroup Shanghai through the means set forth in this Agreement, and PageGroup Shanghai will assist you in notifying the data recipient and supervising the realization of the rights and interests of the subject of the personal information.

You may wish to read Article IX of this Policy to be informed of the specific types of personal information rights to which you, as a subject of personal information, are entitled and the means by which they may be realized.

3. Withdrawal of consent route

You can withdraw your consent by contacting us, please see the 'Contact Us' section of this policy.

Withdrawal of consent does not affect the validity of personal information processing activities that have been carried out on the basis of your consent prior to withdrawal.

PageGroup Shanghai may transfer your personal information to the following entities: entities within PageGroup, third-party service providers in connection with our products or services, our authorities or governmental agencies in order to enhance the quality of our services and products, to process your application for employment, to match you with jobs for which you are qualified, and to refer you to PageGroup's own and our clients' job opportunities.

Your nationality, name, date of birth, gender, current place of residence, contact information, education, employment history, and other information that appears on your resume and is relevant to your job search will be transmitted.

PageGroup Shanghai emphasizes the protection of minors' information.Due to the nature of PageGroup's product content and services, PageGroup Shanghai does not provide services to minors under the age of 14. If you are a minor under the age of 14, please notify your guardian or legal representative immediately and have the guardian or legal representative accompany you to immediately terminate your use of the PageGroup website and do not provide any personal information to PageGroup Shanghai.

We do not intentionally collect sensitive information about you specifically, and before you provide us with any of your sensitive personal information, you have carefully considered and hereby confirm that such provision is appropriate, and you hereby agree that your sensitive personal information may be processed for the purposes and in the manner described in this policy.

Ⅷ. Protecting the security of your personal information

In terms of personal information collection, the application system mandates the use of HTTPS access to ensure the confidentiality of business data; only user personal information that is necessary for the business is collected, stored and used.

In terms of personal information storage, the application system employs the use of login name ＋ static password to identify the logged-in user, which is unique and enables password complexity, login failure lockout and login timeout;the security audit function was enabled, and the audit scope covered every behaviour and important security events of each operating system user, auditing user logins, operations and other events, with all audits turned on for success/failure; the software Apex One Security Agent was deployed, which automatically scans the system for vulnerabilities every day, and at the same time is capable of automatically updating patches pushed out by the system.

For secure transmission of personal information, the application is enabled with a password complexity policy, and Cloudflare WAF employs the HTTPS transport encryption protocol, which prevents eavesdropping of bounded information in network transmissions, protects the data during its transmission, and uses proper protection mechanisms to protect the data from malicious attacks.

We have implemented and will continue to implement appropriate technical and other related measures to protect your personal information from accidental or unlawful destruction, damage, alteration, unauthorised disclosure or access. Only authorised personnel and third party service providers will have access to such personal information where they have a need to know. Furthermore, these persons and service providers are contractually obliged to treat the aforementioned data as confidential.

Ⅸ. How do we store your personal information?

We will store personal information collected and generated by our operations in China in mainland China. In the event that your personal information is viewed or accessed by a recipient outside of China for business purposes in compliance with applicable laws and regulations, we will comply with the requirements of the relevant laws and regulations and take the necessary measures to ensure that the handling of your personal information by the recipient outside of China is in compliance with the laws and regulations.

We will retain your personal information for as long as necessary to fulfil the purpose for which we collected the data, which may be an ongoing purpose. For example, if you are a candidate, we will retain your personal information for the duration of our business relationship with you and beyond, as we often offer candidates more permanent placements and may provide long-term support throughout their careers.

We will retain some personal information for longer than other data. In order to determine the appropriate retention period for personal information, we will take into account the following factors: the purposes for which we process your personal information, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal information we hold about you, and the potential risks to you from unauthorised use or disclosure of your personal information.

Generally speaking, the relevant period is the shortest time necessary to achieve the purpose for which you have authorised the use of your personal information, unless otherwise required by national laws, regulations, rules, normative documents or governmental policies or orders, or for the purpose of retaining your personal information in order to fulfil our compliance obligations, e.g., the "Law of the People's Republic of China on Electronic Commerce" requires that the retention time of information on goods and services, and information on transactions be no less than three years from the date of completion of the transaction; and the "Law of the People's Republic of China on Cybersecurity" requires that technical measures be adopted for monitoring and recording the operating status of the network, and cybersecurity incidents, and that relevant web logs be retained in accordance with the provisions of the Law for a period of no less than six months.

After the storage period mentioned above, we will delete or anonymise your personal data.

In the event that we cease to operate due to operational difficulties or other reasons, unless otherwise stipulated by laws, regulations or normative documents, we will inform you of such circumstances and cease to collect your personal information in a timely manner, as well as deleting or anonymising any personal information that has already been collected.

If we process your personal information for marketing purposes, we will do so shortly thereafter if you ask us to stop the aforementioned marketing practices against you. We will also keep a record of the data you request us not to send you marketing communications so that we can comply with your request.

Ⅹ. Your rights in relation to the personal information we hold about you

1. Access to or correction of your personal information

You have the right to log in and access your account at any time to view your personal information. If you find that your personal information collected, stored, used or disclosed by us is incorrect or incomplete, or in other cases stipulated by laws and regulations, you can make corrections or additional improvements in the following ways.

On the website, you can access or correct your account by clicking on "My Account".

If you encounter difficulties in exercising the above rights, you may contact us in the manner described in Article X of this Policy, and we will respond to your request in a timely manner after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this Policy.

2.Delete your personal information

You may request us to delete your personal data in the following cases, unless the data has been anonymised or unless otherwise provided for by law or regulation:

• The purpose of the processing has been achieved, cannot be achieved or is no longer necessary to achieve the purpose of the processing;
• We stop providing products or services or the retention period has expired;
• If you withdraw your consent;
• We handle personal information in violation of laws, administrative regulations or agreements;
• Other cases stipulated by laws and regulations, etc.

On the web side, you can delete or modify some information by clicking on My Account -> My CV.

When we decide to respond to your deletion request, we will delete your information from our servers as soon as possible, unless otherwise provided by law or regulation. Please be aware that we may not delete the information you need to be deleted from the backup system immediately, but will do so in a timely manner when the backup system is updated.

If you encounter difficulties in exercising the above rights, you may contact us in the manner described in Article X of this Policy, and we will respond to your request in a timely manner after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this Policy.

3. Cancellation of your account

Unless otherwise provided by law or regulation, or as otherwise agreed in this Policy, you may cancel your account in the following ways:

On the web side, you can log out by clicking My Account -> Account Settings -> Close Account.

If you encounter difficulties in exercising the above rights, you may contact us in the manner described in Article X of this Policy, and we will respond to your request in a timely manner after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this Policy.

4. Obtaining a copy of your personal information

You have the right to obtain a copy of your personal information. On the web side, you can download it by clicking on My Account -> My CV.

If you encounter difficulties in exercising the above rights, you may contact us in the manner described in Article X of this Policy, and we will respond to your request in a timely manner after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this Policy.

5. Responding to your request above

In order to fulfil the user rights described in this policy, or if you have any questions, complaints, comments or suggestions regarding your data subject rights, you may contact us in the manner described in Article X of this policy. Subject to relevant legal requirements, your next of kin may exercise the user rights described in this Policy in relation to your relevant personal data, unless you have made other arrangements. For security purposes, we may ask to verify your identity before processing your request. For your request, we will complete the identity verification and response processing within 15 working days of receiving your request.

In principle, we do not charge you for reasonable requests. For requests that are repeated several times within a certain period of time, we will charge a fee for the costs incurred, as appropriate, and for requests that require excessive technical means (e.g. the development of a new system or a fundamental change in current practice) or other significant difficulties, we will provide you with an alternative method.

In addition, you may object to the processing of your personal data in certain circumstances (in particular where we do not have to process your personal data to fulfil a contractual or other legal requirement, or where we use the data for marketing promotions to you).

Of course, please understand that these rights may be limited, for example, if complying with your request would reveal personal information about other people, which would infringe the rights of third parties (including ours); or if you ask us to delete data that we are required to retain by law, or where we are required to retain the data in question on the basis of other legitimate interests. We will inform you of any relevant exemptions we rely on when responding to your request.

Ⅺ. Contact Us

1. Exercise your rights

If you want to exercise your rights, or withdraw your consent to the processing of your personal information, or cancel receiving marketing promotions from us, you can:

• Complete our request form here.
• Write to us or our DPO: privacyofficer@michaelpage.com.cn

DPO:
Shanghai, China
Jing'an District
288 Shimen 1st Road
18/F, Tower 2, Industrial Swire Pacific Place
200041

2. Issues and complaints

If you have any questions about our privacy policy, our handling of your personal information, or need to make a complaint, you can fill out our request form here, or email us or our DPO: privacyofficer@michaelpage.com.cn.

You also have the right to file a complaint with the competent supervisory authority if you have unresolved issues or believe that a breach of personal information has occurred.

3. Changes to our Privacy Policy

We may update this privacy policy from time to time. If we update this Privacy Policy, we will post it on this website.

4. Exit of personal information

If you have any questions about the outbound activities of your personal information and the security protection of your personal information after departure, you can also contact us through the above contact information, and we will convey your needs and assist you in handling them.