Mainland China addendum to JSM recruitment privacy notice

1. This privacy policy applies to candidates applying for a position at JSM’s representative offices and consultancy service provider in Mainland China (“JSM Mainland China Entities”, “We”, “us” or “our”). For information on JSM and the specific JSM Mainland China Entities, please refer to the legal notices section on JSM’s website (www.jsm.com).
2. This Mainland China Addendum supplements and constitutes an integral part of the JSM Recruitment Privacy Notice.

Transferring and Sharing of your information

3. We may transfer your personal information out of Mainland China to JSM in Hong Kong for the purposes of considering individuals for employment and to manage on-boarding procedures if your application is successful. The information may be initially transferred to a Hong Kong service company established by JSM named Sekots & Co., Limited, and located at 16-18^th Floors, Prince’s Building, 10 Chater Road, Central, Hong Kong (the “Overseas Recipient”), which provides the infrastructure located in Hong Kong for us to store and manage your personal information. Then, the information may be accessed by or shared with JSM for further processing to enable the JSM Mainland China Entities to achieve the abovementioned purposes.
4. The personal information that may be transferred outside Mainland China includes:

1. 1. 1. basic personal information, including your name, address, email address and telephone number. If you received or accept an offer form us, additional details including your date of birth, marital status, gender, nationality, country of citizenship, emergency contact, and any dependent information (if applicable);
      2. personal identity information, including ID card and passport*, if you are invited for an interview with us, or when you receive an offer from us.
      3. personal education and work information, including your educational background, work experience, professional qualifications, language skills, work locations;
      4. recruitment information, including your CV, covering letter and references*;
      5. physiological and health information, which may be obtained if you are asked to undergo a health check as a condition of employment with us*;
      6. legal and compliance related information, including disciplinary records* and outside interests (e.g. directorship) collected as part of our background checks if you are made an offer by us;
      7. if you receive and accept our job offer, your personal property information, including your bank account details* (for onboarding related matters);
      8. other information you provide voluntarily during the recruitment process, such as your photograph and compensation details.

5. The above information with an “*” may be regarded as sensitive personal information under the personal information protection law of Mainland China. If you do provide sensitive personal information with us, you agree that such information may be processed by us as described in this Notice.
6. There is no negative consequence if you do not wish to provide us with your personal information in the context of submitting an application. However, without providing your personal information when requested which is necessary for us to consider your application (such as your qualifications or work history), we may not be able to further process your application.
7. If you provide us with personal information relating to other persons (such as your family members, your supervisors etc.) located in Mainland China, you are responsible for ensuring the relevant individuals are made aware of the terms of this addendum and JSM Recruitment Privacy Notice and that you are legally authorized or entitled to provide us with their personal information. You are also responsible for ensuring that their personal information is accurate and up-to-date, and you transfer the information to us in compliance with applicable data protection laws.
8. You will not be subject to decision that will have a significant impact on you based solely on automated decision-marking.

Your rights in connection with personal information

9. As a personal information subject in Mainland China, you have the rights according to the Personal Information Protection Law (“PIPL”) which include the rights to access to, request deleting of your personal information and withdraw consent to our processing of your personal information. We will try our best to support the exercise of your rights according to the law, but please be aware that exercising of your rights may affect the progress of your applications, or we will be subjected to certain constraints. For example, if you would like to delete your personal information provided to us, but the retention period prescribed by the applicable laws and regulations has not expired, or it is technically difficult to delete the personal information, we will cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.
10. If we process your information based on your consent, you will have the right to withdraw that consent. Please be aware that withdrawing consent does not invalidate the processing activities that were carried out based on your consent before the withdrawal.
11. By providing your personal information with us through our online recruitment and candidate management system or providing personal information to us on request, you acknowledge that you have carefully read, fully understood and accepted this Addendum. By accepting this Addendum, you have granted your consent, including the separate consent required under PIPL to authorise us to collect and process your personal information in accordance with this Addendum.

Contact Information

12. If you wish to exercise your data subject rights, including the right to withdraw your consent, you may submit your request via email to our privacy team by using the privacy@jsm.com or use the contact details provided here to reach the JSM Mainland China Entities and the Overseas Recipient.
13. In order to facilitate this process and to enable us to assist you, when you make a request to us, please specify the nature of request, and provide us with your name, e-mail and telephone number, and proof of identity. We will use this information solely to validate your request by matching it with our records.

Last updated: 2 December 2024