If you are contemplating a position with Shell or taking part in a job recruitment process. Information for individuals who apply to work for, or who attend a recruitment event or undertake an assessment with Shell.
What does this Privacy Notice cover?
This Privacy Notice– Shell Group Recruitment provides information about personal data which is processed by a company or companies within Shell in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with a company or companies within the Shell group of companies (‘Shell’). This includes prospective employees, interns and contractors.
This notice explains what personal data is processed, for which purposes, how long we hold the personal data for, how to access and update your personal data and where to go for further information.
For individuals who are successful in their application for employment, internship or engagement as a contractor, the Privacy Notice- Shell Group Employee, Contractor and Dependents’ Personal Data will apply.
Who is responsible for any personal data collected?
Shell Hong Kong Limited, a company incorporated in Hong Kong whose registered office is at 35/F., AIA Kowloon Tower, Landmark East, 100 How Ming Street, Kwun Tong, Kowloon, Hong Kong is responsible for processing your personal data on behalf of itself or the relevant employing or engaging company within Shell.
Notice – if you are under 18 years old and wish to apply for a Shell sponsored education or innovation event or programme
If you are under 18 years’ old (or older if set out in any local privacy notice) please do not send us your personal data (for example, your name, address and email address). If you wish to contact Shell in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.
What personal data do we process?
We process personal information relating to individuals who apply to work for, or who attend a recruitment event and/or undertake an assessment (‘Applicants’) only for legitimate purposes in the following categories:
Human Resources and personnel management
- Applications for employment, results of interviews and assessments:
- Personal contact details;
- Management reporting and analysis including statistical analysis and surveys regarding the quality of the recruitment process;
- Internal audits and investigations;
Pre- screening of Applicants
We carry out screening of all Applicants who we intend to make an offer of employment, engagement or internship (as the case may be) and prior to any offer being confirmed for the purposes of:
- verifying the information that an Applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No steps will be taken in this respect until the Applicant confirms the verification can take place.
- screening Applicants against publicly available or government issued sanctions lists and media sources. This is to comply with legal and regulatory obligations, to protect Shell’s assets and employees/contractors and specifically to ensure that Shell can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements.
Personal data regarding suspected and actual criminal behaviour, criminal records or proceedings regarding criminal or unlawful behaviour may be processed as part of the pre-employment/pre-engagement screening but only for the purposes of ensuring compliance with legal and regulatory obligations and/or to the extent permitted or required by local law.
Automated decision making
All applicants must answer questions which are necessary to ensure that individuals can lawfully enter a contract with a Shell company if they are successful in their application. In addition, for graduate hires, we utilize an online assessment tool which scores individuals on their suitability for employment, based on automated decision making to ensure objectivity. In those cases, you will be notified of this and you will have the opportunity to have such automated decisions reviewed by or on behalf of a member of the Shell recruitment team. Save as specifically notified to you during the recruitment process, no other automated decision making will take place to determine suitability or eligibility for employment or engagement as a contractor.
Special categories of data (‘sensitive personal data’)
For the purposes of recruitment, personal data regarding health data may be processed only as strictly required and as permitted or required by local law for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems.
In addition, in order to ensure equal employment opportunities as permitted or required by local law we may also gather data regarding Applicants, including their nationality, racial and/or ethnic origin.
For what purposes do we process personal data of Applicants?
Personal data of Applicants is only processed:
- in order to take steps at the request of the Applicant prior to entering into a contract;
- where it is necessary to comply with a legal obligation to which the relevant Shell company/companies is subject to ensure compliance with local employment, social security laws and regulations;
- where it is necessary for the legitimate interests of Shell (such as ensuring compliance with legal obligations other than those related to employment or social security, the protection of Shell assets, reputation and Shell employees and contractors) except where such interests are overridden by the interests or fundamental rights and freedoms of the Applicant; or
- (only if legally required) with the explicit consent of the Applicant.
In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
Who will we share the personal data with?
Your personal data is exclusively processed for the purposes referred to above (or for a secondary purpose where it is closely related, for example such as storing it) and will only be shared on a strict need to know basis with:
- Other companies within the Shell group of companies, including to those which may be located outside of your location and/or the Economic European Area (“EEA”); and
- Authorized third party agents, service providers and/or subcontractors of Shell in particular authorised third parties who carry out reference and background checks on behalf of Shell;
- A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell company/companies is subject to or as permitted by applicable local law.
Transfers of personal data
Where the personal data is transferred to companies within Shell and/or to authorized third parties located outside of your country (including outside of the European Economic Area) we take organizational, contractual and legal measures to ensure that the personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal data. These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can request a copy of these by contacting HK-DPO@shell.com or privacy-office-SI@shell.com.
Security of your personal data
Given the nature of the Shell Group your personal data may be transferred to districts/countries outside of your location which may include countries outside of the European Economic Area. Where that happens, we take steps to ensure that your privacy rights continue to be protected in line with Shell internal rules and applicable law. Only if required by local law we will seek your consent to such transfer.
We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.
How long do you hold my personal data for?
We hold personal data of unsuccessful Applicants for no longer than two years after the recruitment process or assessment has completed.
In all cases information may be held for a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate purpose to retain it.
If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Privacy Notice- Employees’, Dependants’ and Contractors’ Personal Data which you will be provided access to or a copy of upon commencement of employment, engagement or internship.
What are the consequences of not providing my data?
Personal data requested and provided by Applicants is required in order to fulfil legal requirements and/or which is required for entering into a contract with you (or in the case of a contractor your employer/service provider). Failure to provide us with the information requested which is limited to that required for these purposes will negatively affect your chances of being selected for any potential employment, engagement or internship.
We aim to keep our information about you as accurate as possible. Applicants can access their personal data, request correction, or deletion of the personal data (but only where it is no longer required for a legitimate business purpose) or request that the processing of their data is restricted. Please contact http://www.shell.com/careers/contact-us.html
Who can I contact for more information?
If you have any issues, queries or complaints regarding the processing of your personal data please contact us at HK-DPO@shell.com, Privacy-Office-SI@shell.com or Shell Group Chief Privacy Officer at Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.
If you are unsatisfied with the handling of your personal data by Shell, then you have the right to lodge a complaint toThe Office of the Privacy Commissioner for Personal Data, whose address is Unit 1303 on 13/F of Sunlight Tower. Please visit https://www.pcpd.org.hk/ for more information.
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Changes to this Privacy Notice
This Privacy Notice may be changed over time. If there is any inconsistency between the English version and the Chinese version of this Privacy Notice, the English version shall prevail. This Privacy Notice was last updated on 1 January 2018.