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CLP Holdings Limited, its subsidiaries and affiliates (“CLP”, “us”, “we”) is committed to implementing the requirements of the Personal Data (Privacy) Ordinance (Ordinance) and all other applicable laws, rules and regulations relating to data privacy by taking all reasonable steps to safeguard potential talents’ personal data from unauthorised access, processing, erasure or other use during collection, holding, processing, using and transfer.

This statement explains our responsibilities and potential talents’ rights with regard to their personal data.

A potential talent is defined as an individual who applies for employment with CLP through online channels or through other means of direct communication (e.g. email or postal mail) or creates a general profile on our online talent community platform (“Talent Community”), as part of CLP’s recruitment and onboarding activities (collectively, “Talent Acquisition”). CLP collects and processes potential talents’ personal data for making recommendations for employment opportunities with CLP, processing job applications and if successful, for employment with CLP.  CLP may, the extent permitted by law and relevant to and necessary for the job, also collect potential talents’ personal data through other sources where relevant and necessary to our Talent Acquisition activities. Other sources may include professional recruiting firms, potential talents’ referees, past employers, employment check, background check providers, professional social media sites (such as LinkedIn) or job recruitment sites where potential talents may have shared their personal information.

The personal data CLP collects include the potential talents’ legal full names, contact information (phone numbers, correspondence address, email address), gender, nationality, identity documents, academic results, professional qualification, past employment history, employment tests results, and reference / background check results, new hire’s onboarding information (including bank account information, spousal information, date of birth, health information, etc.), etc.

We use the potential talents’ personal data in connection with our Talent Acquisition and related activities, and for legitimate human resources purposes. It includes evaluating the potential talents’ suitability for employment through selection tests, assessment interviews, background checks, etc. either directly by CLP or through a third party; determining the preliminary remuneration and benefits package to be offered to successful job applicants; and if an employment offer is accepted, transferring the personal data so collected to be our personnel records.

In cases where potential talents have provided consent to receive notifications from CLP about job opportunities at CLP which may be of interest to them, we may use the potential talents’ personal data to contact the potential talents to notify them of such job opportunities.

We process potential talents’ personal data for the purposes described above (i) when necessary to assess potential talents’ suitability for employment; (ii) if suitable, enter into employment contracts with potential talents; (iii) when necessary for us to comply with a legal obligation; and/or (iv) when necessary for the purposes of our legitimate interests as a recruiter and employer.

CLP may disclose potential talents’ personal data to third parties such as related companies, joint venture, partners, agents, independent contractors, business associates and service providers (including service providers outside Hong Kong and cloud service providers) if it is necessary for any of the purposes stated above, provided that such third parties are under a duty of confidentiality and that they may only use the data for the purposes for which they are supplied.

CLP will disclose data when required to do so by law and may also disclose such data in response to requests from law enforcement agencies or other government and regulatory authorities.

Potential talents are not required to provide their personal data to CLP. However, in the event that potential talents do not provide accurate, complete and updated personal data, CLP may not be able to process their job applications properly or their requests to join our Talent Community at all.

Potential talents are entitled to be informed whether we hold any of their personal data, and to request access to, correct, update and request the erasure of any such data CLP may hold.  Potential talents also have the right to object to the processing of their data where CLP is relying on its legitimate interests as the legal ground for processing.