What kind of personal data do we gather and utilize?

The personal data we collect and use largely depends on the nature of our relationship with you. These relationships are typically classified as:

• Candidates: This includes all individuals who approach us or are engaged by us in the process of seeking or performing work with us or our clients.

• Clients: This includes all individuals or companies we interact with to provide recruitment solutions and services for their business.

• Referees: This includes all individuals we contact to assess our candidates’ abilities and suitability for employment.

• Participants: This includes all individuals who are provided with career transition services, career management services, change programs, coaching, or other services.

We may also gather personal data from you if you reach out to us, for instance, via phone or email, and do not fall into any of the above categories.

Here are some examples of the personal data we may collect from you:

• Your name and contact information, including your address, email address, and phone numbers.

• Your date of birth.

• Your gender.

• Information in your cover letter, resume, and application forms, including your skills, qualifications, employment history, references, goals, and interests.

• Details of your work rights in Hong Kong or other countries.

• Your tax file number and related details.

• Your current and/or desired salary/remuneration package.

• Details of your current and/or previous employment, including the responsibilities undertaken and skills required in your current and/or previous role.

• Information documenting your work history with or through us (including bank account details, salary, and work performance information).

• Aptitude and psychological assessment results.

• The results of background checks.

• Information regarding your COVID-19 vaccination status and/or ability to enter the workplace in accordance with the prevailing Government regulations.

• Other information that you, your referees, or our clients provide to us, including personal feedback and notes of our interactions with you and/or others in relation to your suitability for work with us or through us.

How and why do we collect and utilise your personal data?

We collect and utilise your personal data for various purposes, such as:

• To provide our services to you, including recruitment, career guidance, coaching, and other human resources solutions;

• To assess your suitability for work with us or through us, and to match you with potential job opportunities with our clients;

• To verify your identity, work rights, qualifications, and background information;

• To communicate with you about our services, your applications, assignments, feedback, and other matters;

• To manage our relationship with you, including providing you with support, training, and performance reviews;

• To comply with our contractual, legal, and regulatory obligations, such as tax, reporting, and audit requirements;

• To protect our rights and interests, and those of our clients, candidates, and other stakeholders, such as resolving disputes, enforcing our terms and conditions, and defending legal claims;

• To improve our services and website, such as conducting market research, analysing user behaviour, and obtaining feedback;

• To market our services and those of our affiliates, partners, and third parties, such as sending you newsletters, updates, promotions, and invitations to events, subject to your consent and preferences; and

• To perform any other functions that are incidental or ancillary to the above purposes, or that are otherwise in your interest or for the public good.

We collect your personal data from various sources, such as:

• Directly from you, when you provide it to us through our website, forms, applications, interviews, assessments, or other interactions;

• From third parties, such as your referees, previous employers, educational institutions, professional associations, background check providers, or social media platforms;

• From our clients, when they provide us with information about you in relation to a job opportunity or assignment;

• From our affiliates, partners, and service providers, who assist us in providing our services to you or who collaborate with us in relation to our services; and

• From publicly available sources, such as websites, databases, directories, or publications.

We will only collect and utilise your personal data in accordance with this Policy, the PDPO, and other applicable laws. We will only collect and utilise your personal data for the purposes that we have informed you of, unless we reasonably consider that we need to utilise it for another reason that is compatible with the original purpose, or where we have obtained your consent or are otherwise authorised by law to do so.

How and when do we disclose your personal data?

We may disclose your personal data to various parties, such as:

• Our clients, who may be interested in engaging you for a job opportunity or assignment, or who may require your personal data for contractual, legal, or operational reasons;

• Our affiliates, partners, and service providers, who assist us in providing our services to you or who collaborate with us in relation to our services, such as IT, payroll, marketing, research, training, and professional advisors;

• Our insurers, bankers, auditors, lawyers, and other consultants, who provide us with financial, legal, accounting, or other professional services;

• Government authorities, regulators, courts, tribunals, and law enforcement agencies, who may require your personal data for compliance, reporting, investigation, or other lawful purposes;

• Third parties involved in a corporate transaction, such as a merger, acquisition, sale, or transfer of our assets or business, where your personal data may be disclosed or transferred as part of the transaction; and

• Any other parties that you have consented to or that we are required or authorised by law to disclose your personal data to.

We may disclose your personal data to parties located in Hong Kong or overseas, depending on the nature and scope of our services and the requirements of our clients and partners.

We will only disclose your personal data in accordance with this Policy, the PDPO, and other applicable laws. We will only disclose your personal data for the purposes that we have notified you of, unless we reasonably consider that we need to disclose it for another reason that is compatible with the original purpose, or where we have obtained your consent or are otherwise authorised by law to do so.

We will take reasonable steps to ensure that any parties to whom we disclose your personal data will protect your personal data in a manner that is consistent with this Policy and the PDPO, and that they will only use your personal data for the purposes that we have specified or authorised."

How do we safeguard and retain your personal data?

We implement appropriate technical and organisational measures to protect your personal data from unauthorised or unlawful access, use, disclosure, alteration, or destruction. Some of the measures that we employ include:

• Utilising secure servers, firewalls, encryption, and passwords to store and transmit your personal data;

• Restricting access to your personal data to our authorised personnel, agents, and contractors who have a legitimate need to access it for the purposes of our services;

• Providing training and guidance to our personnel, agents, and contractors on how to handle your personal data in a secure and confidential manner;

• Conducting regular audits and reviews of our data protection policies and practices to ensure their effectiveness and compliance; and

• Reporting and investigating any actual or suspected data breaches and taking remedial actions as promptly as possible.

We will retain your personal data for as long as necessary to fulfil the purposes for which we collected it, or as mandated or authorised by law. The retention period of your personal data will depend on various factors, such as:

• The nature and scope of our services and our relationship with you;

• The type and sensitivity of your personal data;

• The potential risk of harm or liability from unauthorised or unlawful access, use, disclosure, alteration, or destruction of your personal data;

• The applicable legal, regulatory, contractual, or professional obligations or standards that we are subject to; and

• The existence of any disputes, complaints, or claims involving your personal data.

We will securely dispose of or anonymise your personal data when we no longer need it for the purposes for which we collected it, or when we are no longer required or authorised by law to retain it.

What are your rights and choices regarding your personal data?

You possess certain rights and choices concerning your personal data that we collect and utilize, such as:

• Access your personal data that we retain and to procure a copy of it;

• Rectify any inaccurate or incomplete personal data that we hold about you;

• Request the deletion or erasure of your personal data that we retain, subject to certain exceptions;

• Object to or restrict our processing of your personal data for certain purposes, such as direct marketing or profiling;

• Withdraw your consent to our processing of your personal data, where we rely on your consent as the legal basis for such processing;

• Request the transfer of your personal data to another party, where we process your personal data based on your consent or a contract with you and where our processing is carried out by automated means; and

• Lodge a complaint with the Privacy Commissioner for Personal Data of Hong Kong or any other relevant supervisory authority if you are dissatisfied with how we handle your personal data.

You can exercise your rights and choices by contacting us using the details provided below. We will respond to your request as promptly as possible and in accordance with the PDPO and other applicable laws. We may levy a reasonable fee for processing your request, where permitted by law. We may also request proof of your identity and additional information to verify and process your request.

Please note that some of your rights and choices may be subject to limitations or exceptions under the PDPO or other applicable laws or may affect your ability to use our services or website. We will inform you of any such limitations or exceptions when we respond to your request.

How do we utilize cookies and other tracking technologies?

We employ cookies and other tracking technologies on our website to gather and utilize your personal data, such as your IP address, device ID, browser type, operating system, referring URLs, page views, duration of visit, and other online activities. Cookies are small text files that are stored on your device when you visit our website. They assist us in enhancing our website’s functionality and performance, improving your user experience, remembering your preferences and settings, delivering pertinent advertising and marketing, and analyzing our website traffic and user behavior.

We employ various types of cookies on our website, including:

• Essential cookies, which are indispensable for the operation of our website and services, such as enabling you to log in, access secure areas, and complete transactions;

• Functional cookies, which permit us to remember your choices and preferences, such as your language, location, and display settings;

• Analytical cookies, which assist us in measuring and analysing how you utilise our website and services, such as which pages you visit, the duration of your stay, and what you click on;

• Advertising cookies, which enable us and our partners to deliver pertinent and personalised ads to you on our website and other platforms, based on your online activities and interests; and

• Social media cookies, which allow you to share our content or interact with our social media platforms, such as Facebook, Twitter, and LinkedIn.

You have the option to modify your browser settings to block or delete cookies. However, please be aware that this may affect the functionality and performance of our website and services. For more information on how to control cookies, please refer to the following website: AboutCookies.org

We may also employ other tracking technologies on our website, such as web beacons, pixels, tags, and scripts, to gather and utilize your personal data for purposes akin to those of cookies. These technologies are embedded in our website or emails, enabling us to monitor your online activities and interactions.

We may also engage third-party services, such as Google Analytics, to gather and utilize your personal data for analytics and advertising purposes. These services may employ their own cookies and other tracking technologies to gather and utilize your personal data on our behalf or on their own platforms. For more information on how these services utilize your personal data and how you can opt out of them, please refer to their respective privacy policies and opt-out pages.