What is the purpose of this Privacy Notice?
Third Bridge Group Limited and its affiliates in other jurisdictions (collectively “Third Bridge”) are “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the applicable privacy laws, i.e Personal Information Protection Laws (PIPL) in People’s Republic of China (PRC) including and other relevant Chinese rules and regulations and the General Data Protection Regulation ((EU) 2016/679) (GDPR) which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent and necessary way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
- Third Bridge is the data controller and is accountable when it comes to processing your personal data.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in any curriculum vitae and covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address.
- Any information you provide to us during an interview in person, over the telephone or joining virtually.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies, from which we may collect recruitment information (including copies of right to work documentation, references and other information which you may have provided to the recruitment agency or included in a CV or cover letter or as part of the application process).
- Background check provider (if relevant to the job role), from which we may collect information about criminal convictions and offences
- Credit reference agency (if relevant to the job role), from which we may collect details of any county court judgements and/or financial related (CCJs) or relevant financial information.
- Your named referees, from whom we may collect verification of prior employment.
- We may collect data from third parties that is from a publicly accessible source such as professional networking sites.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable to the job role.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to consider whether or not to appoint you to a particular role that we have advertised and you have applied for. This is because we require operational efficiency and capacity to continue successfully and as a part of that, we need to appoint individuals to vacant roles as soon as possible.
We also need to process your personal information to decide whether to enter into a contract of employment/ temporary engagement (as appropriate) with you.
Having received your CV and covering letter, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview either over the telephone and/or in person. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references, carry out a criminal record and/or carry out a credit reference check (if relevant to the role) before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Information about criminal convictions
We may process information about criminal convictions.
If relevant to the role, we may collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular if the role of requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.
We have in place appropriate safeguards which we are required by law to maintain when processing such data.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data sharing
Why might you share my personal information with third parties?
We will only share your personal information with wholly owned subsidiaries of Third Bridge Group Limited or the third party recruitment company you were introduced to us through (if any) for the purposes of processing your application. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transmission
Export outside the EEA or UK
If you are a candidate in the UK or EEA, note that because we operate globally and for the centralized management of our talent, we may need to transfer your personal information to the subsidiaries of the Third Bridge Group Limited, located outside the European Economic Area (EEA) or UK.
If we do store or transfer data outside the UK or EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR or in the EEA under GDPR (as the case may be).
Your acceptance of this Privacy Notice shall be your consent permitting us to store or transfer data outside the UK and/or EEA if it is necessary for us to do so.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Export outside the PRC
If you are a candidate in the PRC, given the business is global, note that because we operate globally and for the centralized management of our talent, we may need to transfer your personal information (including categories listed below) to the Third Bridge Group Limited, located outside the PRC, via the Internet and our intranet connecting our information systems.
- Personal basic profile including name, title, phone number, email address, CV/profile, place of residence.
- Personal education and work (job application) information including working department, report line, position, interview record, offer detail, interview information (process, date, time, location, feedbacks), certification information, work experience, education background, working permit status, message to hiring manager.
The overseas data recipient is the Third Bridge Group Limited, a company registered in England and Wales (company number 06263699) with the contact address at the Steward Building, 12 Steward Street, London, E1 6FQ. The overseas data recipient in the UK may use information systems deployed on servers in other jurisdictions/regions (including USA, Germany, Ireland, France) to receive personal information that we transfer and conduct the further processing.
If we do store or transfer data outside PRC, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the PRC and under the PIPL.
Your acceptance of this Privacy Notice shall be your separate consent permitting us to store or transfer data outside the PRC if it is necessary for us to do so.
In addition, we will take necessary measures required by PIPL including entering into standard contractual clauses with the overseas data recipient to stipulate the rights and obligations between us, and will ensure that the overseas data recipient provides adequate protection for your personal information under applicable laws.
We will only transfer your personal information to the extent necessary and will work with the overseas data recipient to process it in a secure manner to protect your legitimate interests and to avoid causing harms to you. We and the overseas data recipient will only retain your personal information for the minimum necessary retention period unless otherwise required by applicable laws.
You have the right to exercise your personal information rights against the overseas data recipient by sending an email request to dpo@thirdbridge.com. Under our agreement for the cross-border transfer of personal information with the overseas data recipient, you could be considered as a third-party beneficiary and can be entitled to exercise the third-party beneficiary rights if you do not expressly refuse within 30 days upon your acceptance of this privacy notice. According to applicable laws and the standard contractual clauses between the overseas data recipient and us (if applicable), you may have the right to demand us to provide a copy or a summary of the relevant contract content.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer.
We have put in place procedures to notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
We may also retain your personal information on file for a further 12 months, on the basis that a further opportunity may arise in future and we may wish to consider you for that and we will seek your consent to do so during the online application process. If you object to us retaining your personal information for a further 12 months please notify us at dpo@thirdbridge.com.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure/deletion of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer by email at dpo@thirdbridge.com.
In certain circumstances we may not be able to respond to your rights. In such circumstances the Data Protection Officer will promptly communicate such reasons to you via email.
Data protection officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at dpo@thirdbridge.com.
Your Right to make a Complaint
You have the right to make a complaint at any time to the competent authority in your jurisdiction (Authority) i.e China’s government authority in charge of the protection of personal data (‘CGA’), the Privacy Commissioner for Personal Data, Hong Kong (‘PCPD’) or Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Authority so please contact us in the first instance. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
This Privacy Notice was last updated in July 2023.
