Privacy Policy - Hong Kong

Chandler Macleod Group (HK) Limited (“CMG”, “us”, "we" or “our”) understands and appreciates your concerns about privacy and the confidentiality and security of your personal data.  As such, CMG is committed to complying with the Personal Data (Privacy) Ordinance and the Data Protection Principles as amended from time to time.

This Privacy Policy Statement details how we comply with our privacy obligations and how we manage the personal data you provide to us. By submitting personal data to us, you agree to our use of such information as described herein. We reserve the right to make changes to this Privacy Policy Statement from time to time and all personal data held by us will be governed by the most recent version of our Privacy Policy Statement.

Your use of the CMG site in Hong Kong, available at www.chandlermacleod.asia (the “CMG Site”), is subject to this Privacy Policy Statement. You may not use the CMG Site if you do not agree to this policy.

1. What is personal data?

The Personal Data (Privacy) Ordinance (“PDPO”) defines personal data. Personal data includes information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. In summary, personal data is any information that can be used to identify you. If the information you provide to us identifies you or your identity can be reasonably ascertained from such information, it will be considered personal data and we will manage such information in accordance with the PDPO and the Data Protection Principles (“DPP’s”), as defined, and this Privacy Policy Statement.

2. What information do we collect?

We collect personal data in a variety of ways, including via the CMG Site (such as when users register, apply for employment), when you respond to e-mail questionnaires or when you provide personal data to us by other means, such as in person, over the phone or by email. The personal data collected may consist of your actual name, a unique site access ID, company or educational affiliations, qualifications, titles, contact information, information from your CV and other information from which you may be identifiable. You also agree that we  may also collect and disclose personal data about you from and to our service providers, business affiliates, clients and other third parties such as employers and persons nominated by you as referees.

Some information that we collect may not be personal data. This may include aggregated information about how users use the CMG Sites, anonymous answers to surveys and other information that does not personally identify you. Information that is not personal data is not subject to the PDPO or the DPPs and we can use such information for any purpose.

3. How may my personal data be used?

We collect personal data about you so that we can perform our business activities and functions and to provide the best possible quality service to you. We collect, hold and disclose your personal data for the following purposes:

  • to provide our services to you, including to fulfill your requests for information and employment opportunities and to manage the recruitment process for third parties and ourselves;

  • to manage our client and business relationships;

  • to provide assessment and other consulting services;

  • to provide you important work related information including workplace health and safety, work rosters and other information relating to your engagement by CMG;

  • to undertake psychometric testing;

  • to perform statistical analyses of user behaviour in order to measure interest in specific areas and articles posted on the CMG Site.  The e-mail addresses provided at registration allow us to send e-mail to individuals based on the areas of interest that they may indicate during the employment registration process;

  • to send communications requested by you, answer enquiries and provide information about existing or new services;

  • to provide your updated personal data to related bodies corporate, our customers, contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services to you;

  • to update our records and keep your records up to date;

  • to process and respond to any complaint made by you; and

  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any country.

4. Are cookies and IP addresses used?

The CMG Site uses “cookies” to identify you and your interests and to track usage of the CMG Site in order to help personalise your browsing experience. Cookies are small pieces of text stored on your computer that help us know which browser you are using and where you have been on the CMG Site and on web sites to which you may link in order to use some of our features. Cookies also let us know whether you have registered with us and otherwise enable us to relate your current usage of the CMG Site to your prior usage. If you do not wish to receive cookies, you can set your browser to refuse them. However, a user who does not accept the cookie from the CMG Site may not be able to access certain areas and may limit your use of the CMG Site and some of our services. In administering the CMG Site and diagnosing potential system problems, we also log all IP addresses which access the CMG Site.

5. Is personal data disclosed to third parties?

We may disclose your personal data to:

  • our customers;

  • contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services to you;

  • our employees, related bodies corporate, contractors or service providers for purposes of operation of our website and to fulfill your requests including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors and professional advisors such as accountants, solicitors, business advisors and consultants;

  • any organisation for any authorised purpose with your express consent; and

  • should we intend to merge with, or sell the majority of our assets or equity to a third party, personal information may be disclosed to that third party.

We may transfer personal data about you to someone who is in a foreign country if:

  • you consent to the transfer; or

  • we have taken reasonable steps to ensure that the information that we have transferred will not be held, used or disclosed by the recipient of the information inconsistently with the DPP.

We will not intentionally disclose (and will take commercially reasonable steps to prevent the accidental disclosure of) your personal information to third parties, whether for such third parties' marketing purposes or otherwise, except when we believe we are under a legal duty to do so.

If we are unable to collect your personal information, we may be unable to fulfill some or all of the purposes listed above.  In particular, we may be unable to provide our services to you or provide you with full access to the CMG Site.

6. Direct Marketing

To keep you informed about CMG’s new services and job opportunities we will use your personal data for direct marketing of our services. However, we will not use your personal data for this purpose unless we have received your written consent or indication of no objection.

7. Links to third party sites

This Privacy Policy Statement applies to the CMG Site. We may provide links to third party websites as a service to our users. We cannot control or accept responsibility for the information collection practices of such third parties. We encourage you to review and understand the privacy policies of the relevant third parties before providing any information to them.

8. How can I access, correct or change information?

Subject to some exceptions in the PDPO, you have the right to access and correct personal data about you that we hold. You may access and update personal data that you submitted to us directly or through the CMG Site. To do so, please send us a Personal Data Access Request e-mail at hongkong@chandlermacleod.com, together with sufficient information to allow us to confirm your identity (generally speaking, a scanned copy of photographic identification will suffice). As soon as practicable after your request is received, your personal data will be deleted from our database. You should be aware that we are required by law to retain certain personal data (such as payroll records); such information will not be deleted. We will let you know if we cannot delete your personal data for legal or other reasons. Of course, if your personal data has been deleted and you wish to apply for another position through us, you will need to repeat the application process.

There may be times when we cannot grant you access to the personal data we hold. For example, if access would interfere with the privacy of others or if it would result in a breach of confidentiality or law, we will not be required to grant you access. We will let you know if this is the case.

9. Security

We have in place industry standard technological and operational security in order to protect your personal data from misuse and unintended disclosure, alteration, or deletion. Only authorised personnel will be provided with access to personal data. These parties are required to treat this information as confidential and in accordance with this Privacy Policy Statement.

As the CMG Site is linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any information which you transmit to us online is transmitted at your own risk.

10. Contact our Data Protection Officer

If you have any questions in relation to our Privacy Policy Statement. or any complaint regarding the treatment of your privacy by us, please contact our Data Protection Officer at hongkong@chandlermacleod.com

General information about privacy may be found via the Privacy Commissioner’s website http://www.pcpd.org.hk.