Thank you for trusting and using the services of Robert Half Human Resources Shanghai Company Limited ("We", "we", or "RHC"). When you use the RHC website "www.roberthalf.cn" (the “Site”) or register for services in connection with the Site, we will ask you to provide us with certain personal information. We are fully aware of the fact that your personal information is important to you, so we will try our best to ensure the security and reliability of your personal information. We promise that we will take appropriate security measures to protect your personal information in accordance with the industry-proven security standards.
This policy is intended to explain to you how we collect, use, share, and protect your personal information. Please read and understand the entire content of the Policy carefully, and confirm your full understanding and consent before using the Site. We try to express the Policy in plain, concise words, and use "underline" to indicate the terms in the Policy that have a significant relationship with your rights and interests. Once you provide us with your information or begin to use the services of the Site, you are deemed to have read, understood and agreed to accept the Policy.
If you have any questions, complaints, comments and suggestions about the Policy, you are welcome to communicate and give feedback through the contact information attached to the Policy; we are very glad to answer your questions.
The Policy will help you understand the following information:
- RHC privacy protection principles
- Relevant definitions of the Policy
- What kind of personal information is to be collected
- How we use your personal information
- How we entrust the handling, sharing, transfer or making available your personal information
- How we protect your personal information
- Your rights
- Protection of minors
- How your personal information will be transferred globally
- How the Policy will be updated
- How to contact us
RHC privacy protection principles
We are committed to maintaining your trust in us and observing the following principles to protect your personal information:
1. Guarantee of security
We will try our best to prevent your information from being disclosed, damaged or lost through reasonable and effective information security technology and management processes.
2. Minimum necessary amount
We will only collect and use the minimal amount of personal information based on business necessity.
3. Openness and transparency
We will be transparent about how and why we handle your personal information.
4. Solicitation of consent
Unless otherwise provided by laws and regulations, we will obtain your consent before collecting and processing your personal information.
5. Involvement of personal information subjects
In applicable situations, we will protect your privacy and control rights over your information. At the same time, we provide you with ways to raise objections and complaints to us.
• Relevant definitions of the Policy
1. The objective protected by the Policy is the personal information of any applicable object, and the personal information referred to in the Policy means any information saved in electronic form or otherwise that can be used independently or together with other information to identify a natural person or reflect the activities of a natural person, such as names, dates of birth, identification numbers, personal biometric information, addresses, contact information, records and content of communications, passwords of accounts, property information, credit reference information, whereabouts and tracks, hotel accommodation information, information concerning health and physiology, information on transactions, etc.
2. Personal sensitive information means personal information that may cause harm to personal or property security, or is very likely to result in damage to an individual's personal reputation or physical or mental health or give rise to discriminatory treatment, once it is leaked, unlawfully provided or abused, such as information concerning property owned by an individual (including bank accounts, real estate information, credit loan records, credit reference information, information about virtual property, etc.), identification information of an individual (including identity card, military officer certificate, passport, driving license, work license, building pass, social insurance card, residence permit, etc.), information concerning online identification symbols (including account of a personal information subject, code, answers to questions asked to protect the code, a personal information subject's personal digital certifications for the said account or addresses, etc.), biometric information of an individual (including personal genes, fingerprints, iris, facial features, etc.), and other information (including information on hotel accommodation, web browsing history, information on accurate positioning, etc.).
In the Policy, we will clearly identify personal sensitive information by "italic and bold" font.
• What kind of personal information is to be collected
1. When you use RHC services
(1) The personal information provided to us by you
A. The personal information you must provide to us:
When you use the services of the Site, we need to rely on some personal information that you actively fill in and submit on the Site in order to run the relevant services. Without the information, we may not be able to provide you with all the services of the Site you have requested.
When you use the function about" Subscribe to the Robert Half newsletter", we need you to provide us with your name, email, and your subscription of your choice.
When you use the function about "Request talent", you need to provide us with your job description, recruitment requirements, contact name, business phone, work email and company name.
When you use the function about "Submit Resume", in order for our professional consultants to assist you in your job search, you need to provide us with your name, email, phone number, available time, your job search criteria and preferences(including but not limited to the industry, the job type and the location of the office corresponding to your job intent),work experience, education, skills, reference information, background information and additional information included in your resume.
When you use the function about "Salary Guide", you need to provide us with your name, email and the type of service you want RHC to provide for you to help you access the most up-to-date salaries and remuneration trends in your industry.
(2) the information collected by RHC automatically
When you use the services on the Site, we automatically collect information about the content of the services you use and how you use the services, including the personal information.
A. Location information
When you use certain functions of the Site, we may collect your accurate or approximate location information, which is determined by your IP address or GPS data of your mobile device, in order to provide you with a better user experience. Most mobile devices allow you to control or disable the use of location services in the devices’ setting menu. Even when you are not using the services on the Site, if your settings or device permissions allow the location information connection to be turned on, we can still collect such location information. Of course, if you refuse to grant us the appropriate access to the location information, we will not record your relevant information.
B. Usage information
We will collect the information about your interactions with RHC on the Site, such as the pages or other contents you view, the services you search for and other activities on the Site.
C. Login and device information obtained using cookies and similar technologies:
In addition to cookies, we also use web beacons and other similar technologies on the Site. The web beacon is a transparent image embedded in a website or an email. With the help of the web beacon in an email, we can know whether the email is opened and track the email. For example, the email we send you may contain a URL link to our Site. If you click on that link, we will track the click to help us know your service preferences and improve our service quality.
2. The information we get from other sources
(1) From third-party services:
If you associate your RHC account with a third-party service (such as WeChat) or log in to your RHC account using a third-party service, the relevant third-party may send us your registration information and personal information in the relevant service. The specific information varies from service to service and is controlled by the relevant service or authorized by you through the privacy settings of the relevant service.
(2) Other legitimate sources:
We may obtain your personal and other information from other legitimate sources, such as public databases, social media, third-party service providers, and other partners.
• How we use your personal information
The personal information and other related information we collect from the above methods may be used for the following purposes:
|The contents of the information||The purposes of the information|
|essential information (such as name)||We can understand your basic situation through the information.|
|contact information (such as name, phone number, business phone and email).||We can communicate with you and contact you through the information so that you can use the services provided by RHC smoothly.|
|recruitment or job search information (such as the job description, recruitment requirements, company name provided by the recruiters, and the available time, job preferences, work experience, education, skills and additional information included in the resume provided by the candidates)||1.The information helps us achieve the most basic human resources service, that is, recruiting talents for the recruiters and matching suitable positions for the job seekers. We use the recruitment or job search information which you provide to conduct job assessments and select and recommend the candidates or jobs for you.
2. The information helps us understand your recruitment standards or job preferences, and we can send you targeted messages, emails, WeChat, phone invitations, advertisements, recruitment information and other information or marketing materials you may be interested in. You can opt out of receiving such automated email messages or marketing materials by sending a message to “[email protected]”.
|Identification information (such as social security card number, employee ID)||The information is used to identify and verify your identity in order to prevent fraud, abuse, security incidents and other harmful activities.|
|Usage information and device information (such as details of your use of the Site, IP address, access dates and times, hardware and software information, device information, UID, crash data, pages you have viewed or accessed before and after using the Site, browsing information, clicking information and other cookie data)||The information helps us understand how and under what network environment you use our services, so that we can provide you with better services and respond to your needs in a targeted manner. For example, we know your preferences and occupations of interest through the information to improve service quality and optimize service functions.|
|The information about selecting the service content (such as your subscription of your choice, the type of service you choose in the function about "Salary Guide" that you want RHC to provide for you)||Provide you with personalized and customized services according to the needs in the information you submit. Through these services, you can keep up to date with the latest industry trends and improve the efficiency of your recruitment or job search.|
In addition, all the above information can be used for our analysis and research work. We are always committed to analyzing and researching the creation of professional opportunities, and devoting ourselves to the cultivation of professional ability, analysis of professional situation and research on employment policies. Therefore, in some cases, we may use your personal information, but we will deal with it according to legal regulations, such as de-identifying and anonymizing the information, to ensure the security of your information.
• How we entrust the handling, sharing, transfer or making available your personal information
1. Entrusted processing
Some specific modules or functions on the Site are provided by external vendors. For example, we will hire a service provider to assist us in providing users support and completing some business functions. Such functions may include, for example, hosting our web servers, analyzing data, providing legal, accounting and marketing services.
For companies, organizations and individuals whom we entrust to handle personal information, we will sign strict confidentiality agreements with them, requesting them to process personal information by taking relevant confidentiality and security measures in accordance with our instructions and the Policy.
(1) We will disclose information to our customers where necessary and appropriate in connection with the provision of staffing services. The core business function of RHC is to become a medium between job seekers and recruiters. RHC not only recommends qualified candidates for recruiters, but also formulates career plans for job seekers. Therefore, sharing the personal information of the job candidates to our recruiting customers and sharing the personal information of the staff of the recruitment companies to the job candidates are our necessary service functions. In addition, we are committed to sharing personal information only for the purposes of the RHC services specified in the Policy.
(2) We may disclose information to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws, the services of legal process, or if we reasonably believe that such action is necessary to (A) comply with the law requiring such disclosure; (B) protect the rights or property of RHC or its affiliated companies; (C) prevent a crime or protect national security or (D) protect the personal safety of the users or the public.
We will not transfer your personal information to any other company, organization or individual, except under the following circumstances:
(1) Transferring information with specific consent, and we will transfer your personal information to other parties, after obtaining your specific consent.
4. Public Disclosure
We will publicly disclose your personal information only under the following circumstances:
(1) After obtaining your specific consent;
(2) Disclosure under applicable law: we may publicly disclose your personal information as required by laws, under legal procedures, in lawsuits or upon compulsory requirements of competent authorities under the government.
• How We Protect Your Personal Information
1. We have put in place safeguards that meet the industry standards to protect your personal information, to prevent data from being accessed without authority, publicly disclosed, used, modified, damaged or lost. We will take all reasonable and feasible measures to protect your personal information.
2. We will take all reasonable and feasible measures to ensure that we have not collected irrelevant personal information. We will only retain your personal information for a limited period necessary for realizing the purposes specified in the Policy, unless it needs to extend the retention period or it is protected under the law.
3. As the internet environment is not one hundred percent safe, we will try our best to ensure the security of any information you send to us.
4. In the case of any unfortunate incident in respect of personal information security, we will, in accordance with requirements set out in laws and regulations, inform you promptly of the particulars, including basic information about the security incident and the likely impact, what measures we have taken or will take to respond to this incident, suggestions on what measures you may take yourself to guard against and lower risks, remedial actions we offer to you, etc. We will brief you on the progress of the incident by email, correspondence, or phone or by sending notifications, and we will release announcements for this purpose in a reasonable and effective manner even when it is difficult to notify personal information subjects one by one. Meanwhile, we will voluntarily report how the personal information security incident is handled, as required by the regulator.
• Your Rights
We guarantee that you can exercise the following rights over your own personal information, according to applicable Chinese laws, regulations and standards, and common practices in other countries and regions.
1. Accessing Your Own Personal Information
You have the right to access your subscription information, delivery information and other information generated on the Site. If you want to access this information, you can contact us by sending an email to ““[email protected]” and we will try our best to comply with your requirements.
2. Updating Your Personal Information
If you want to update the information you submitted, you can request us to correct your original information by sending an email to “[email protected]” including but not limited to your resume, subscription information and contact information.
3. Deleting Your Personal Information
Under any of the following circumstances, you may raise a request for deletion of your personal information by contacting “[email protected]”:
(1) When our processing of personal information violates laws or regulations;
(2) When our processing of personal information violates our agreement with you;
(3) When you no longer use our products or services.
If you request us to delete your information, RHC will remind you of the following:
(1) We may retain some of your personal information for our legitimate business interests, such as the fraud detection and prevention, and enhanced security.
(2) In order to comply with our legal obligations, we may retain and use some of your personal information. For example, RHC may retain some of your information for tax, legal reporting, and auditing purposes.
(3) Once your information has been removed from our services, we may not immediately delete the corresponding information from the backup system, but will delete the information when the backup is updated.
4. Changing the Scope of Your Authority
Each business function on the Site cannot be realized without some necessary information you provide. In terms of the non-essential information that you can provide at your discretion, you can withdraw your authority and consent by contacting “[email protected]”.
When you withdraw your consent, we will no longer process the relevant information. However, your decision to withdraw your consent will not affect the processing of the information previously based on your authorization.
5. Stopping using RHC products or services
You can contact us through the ways listed in the "How to contact us" section, and stop using RHC products or services. After you contact us, we will cease providing you with RHC products or services after we agree, and delete your personal information upon your request. However, in certain circumstances, such as reasonably necessary to fulfill our legal obligations, resolve disputes, and prevent fraud or abuse, we will retain some unidentifiable personal information after we cease providing you with RHC products or services.
6. AI search and match capability
Our success is dependent on efficiently matching candidates to customers’ vacancies. In this context we use artificial intelligence (AI) provided by a third party based in the European Union as this assists our recruitment consultants to perform the search and match of proposed candidates with customer job vacancies more efficiently. The benefit of the AI search capability is that it supports our recruitment consultants to search more CVs and match personal data against customers’ job vacancies faster, ignoring irrelevant data. Our recruitment consultants are presented with a list of proposed candidates that are potentially suitable for a customer’s vacancy but it does not lead to automated decision-making. Our recruitment consultants decide which candidates to shortlist for a specific customer’s job, based on their expertise, knowledge of the job market, insight into the customer’s business and requirements for the role, candidate discussions and other relevant criteria. Customers (through their hiring personnel) decide which candidates to select for interview (if any). Our customers’ hiring personnel (not our AI tool) make the final decision on which candidate to select for their job (if any) and ultimately to proceed to hire/engage/employ the candidate.
If you object to the processing of your personal data by our AI tool, our recruitment consultants will continue to provide work finding services using other methods to search for job opportunities for you. The personal data of candidates who are no longer available for work, not actively seeking a job, have recently commenced permanent employment or who object the processing of their personal data by AI, will be deleted by our AI service provider.
7. Responding to Your Requests
We will give you a definite reply as soon as possible for your reasonable requests. We may refuse your requests if they are repeated without reason, need to be replied through too many technical methods (for example, a new system needs to be developed by the Site or the existing common practices need to be fundamentally reformed), pose risks to others' legal rights or interests, or are fairly unrealistic.
Under any of the following circumstances, we will not respond to your requests:
(1) Where requests are in relation to the performance by the personal information controller of obligations specified in laws and regulations;
(2) Where requests are in direct relation to the State security or national defense security;
(3) Where requests are in direct relation to the public security, public sanitation, or major public benefits;
(4) Where requests are in direct relation to criminal investigations, prosecutions, court trials, execution of rulings, etc.;
(5) Where we have sufficient evidence that the personal information subject is subjectively malicious or abusing your rights;
(6) where requests are for the sake of safeguarding significant legal rights and interests, such as the life and property, of personal information subjects or other individuals, but it is difficult to obtain their consent;
(7) Where responses to your requests will give rise to serious damage to the legal rights and interests of the personal information subject or any other individual or organization; or
(8) Where requests involve trade secrets.
• Protection of minors
Except as required by law, we do not knowingly collect personal information from minors (under 18 years of age). The Site is not open to minors. If you are a minor, please do not provide us with your personal information.
• How your personal information will be transferred globally
Since Robert Half is a global multinational organisation, the overseas transfer of your personal information is necessary as our candidate database infrastructure is hosted outside of the People's Republic of China. We will comply with applicable Chinese laws, regulations and standards when we transfer your information overseas. If we do not obtain your specific consent for overseas transfer, we may be unable to process your application.
• How the Policy will be updated
Our Policy may be changed, so we will publish any changes made here for your review. In the case of major changes, we will post a 30-day notice of the revised Policy on the homepage of “www.roberthalf.cn”, while establishing a link to the change notification page on the homepage.
For the purpose of the Policy, major changes include but are not limited to:
1. Significant changes to our service mode, such as the purposes of processing personal information, categories of personal information to be processed, the ways to use personal information, etc.;
2. Drastic changes to the ownership structure, organizational structure, etc., such as changes to the owners as a result of business adjustments, bankruptcy, mergers and acquisitions;
3. Changes to the subjects we share with, transfer to or publicly disclose personal information;
4. Significant changes to your rights in respect of your participation in personal information processing and to the ways in which you can exercise such rights;
5. Changes to our department responsible for the security of personal information, contact information of such department, or complaint channels; and
6. Changes made due to high risks revealed in the security impact assessment report for personal information.
• How to contact us
If you have any concerns or questions about on the Policy, you can contact us by the following means:
Email: [email protected]
Robert Half Human Resources Shanghai Company Limited
Room 1912-14, 19th Floor
Shanghai Two ICC
No 288 South Shaanxi Road
Shanghai 200031, China
Phone: +86 21 6032 0555
*The Policy was updated on 27 February 2023 and will be effective from 27 February 2023.