Current or former Shell employee, contractor or dependent

This notice sets out what personal data we collect, for what purposes and your rights in this respect.

What does this Privacy Notice cover?

Every individual within the Shell group of companies (‘Shell’ or ‘we’) is responsible for protecting personal data about each other as well as that of our customers, business partners and suppliers.

This Privacy Notice provides information about personal data processed by Shell in relation to individuals who are or were employees, interns or individual contractors as well as dependents of Shell employees (‘Shell Staff’).

For individual retail customers, members of Shell loyalty programs, visitors of Shell websites or users of Shell applications, please refer to the Privacy Notice - Motorists, Loyalty or Energy Customers, Shell App Users and Visitors to our Websites at https://www.shell.com.cn/en_cn/privacy/b2c-notice.html.

For individuals who apply to work for Shell, or who attend a recruitment event or undertake an assessment for Shell, please refer to the Privacy Notice - Shell Group Recruitment at https://www.shell.com.cn/en_cn/privacy/job-applicant-notice.html.

As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we process your personal data in relation to specific HR processes (such as Open Resourcing, OneHealth IT and International Mobility programs). In those instances, such privacy notices will be communicated to you separately.

This Privacy Notice explains what personal data are processed about you, why and how we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

The categories of personal data we collect about you.

What personal data do we process about you? Collection of information

We process personal data necessary to conclude and perform the employment contract with you, to implement human resources management, to engage contractors and interns and to provide benefits to certain dependents of Shell employees.

This includes name, personal identity number, address, contact information, nationality, gender, date of birth, marital status, medical and health status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country/ies you are engaged in, as well as any other information necessary for managing the employment relationship, for engaging contractors and for providing benefits to certain dependents of Shell employees (such as those dependents who accompany a Shell employee while on an expatriate assignment), personal data which has been published by you or published lawfully, other relevant personal data needed to perform your employment contract or proceed human resource management.

Sensitive personal data

We also process some special categories of personal data (’sensitive personal data’) such as personal ID card, driving license, data relating to an individual’s medical and health, financial account, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, marital status, political opinions and personal data of minors under the age 14. We will only process such personal data where it is necessary for the purposes:

• to conclude and perform your employment contract and implement HR management;
• to comply with employment and social security laws;
• for the establishment, exercise or defense of claims;
• where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health;
• or where the individual has provided their explicit consent, including when legally required.

Personal data of minors

For specific HR management purpose, such as to enroll your child/ren who is/are minors to our supplementary/commercial insurance plan, you will be required to provide personal data of your child/ren who is/are minors. Such information include names and personal ID/passport number. We will only process such personal data of minors where it is necessary for these specific purposes.

We will only process your personal data where we have a legal basis to do so.

Why do we process your personal data?

We process your personal data:

• in order to satisfy our obligations to comply with local laws and regulations;
• to conclude, manage and perform under the employment contract with you or to implement human resources management (for example performance management in order to ensure we have qualified and competent personnel or for health, safety and security purposes to ensure that only authorised personnel can access certain sites or assets, internal investigation, litigation and defense of claims);
• where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of a natural person in the case of an emergency;
• where the personal data, which have already been made public, is processed within a reasonable scope; or
• any other circumstance as provided by local laws or regulations; or
• where we have your explicit consent (if required by law).

Please note that as a general principle, Shell does not seek or rely on the consent of Shell Staff for processing personal data, unless otherwise required by applicable local law.

Personal data requested from Shell Staff are the minimum required in order to fulfil legal and/or contractual requirements and to provide opportunities to take part in programs or to provide a benefit. Failure to provide us with the information requested (including the sensitive personal information) may negatively affect your ability to remain in employment, internship or engagement as a contractor or from participating in a program or receiving a benefit.

In those cases where processing is based on consent, and subject to applicable local law which may provide 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. Withdrawal of consent may however impact your ability to remain employed or otherwise engaged or from participating in a program or receiving a benefit.

The purposes for which we process your personal data.

For what purposes do we process your personal data?

We process personal data covered by this Privacy Notice for the following purposes:

• Human Resources, personnel management, business process execution, internal management, management reporting, organisational analysis and development - including budgetary, financial and organisational planning, administration, compensation, performance management;
• Health, safety and security - including protection of Shell Staff’s life or health, occupational health and safety, protection of Shell assets and authentication of Shell Staff status and access rights; or
  
• Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.

We may also process your personal data for a secondary purpose where it is closely related, such as:

• storing, deleting or anonymising your personal data;
• fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
• statistical, historical or scientific research.

Monitoring

• for health, safety and security purposes,to prevent fraud and specifically the protection of Shell assets, Shell Staff and visitors to Shell premises;
• to comply with legal and regulatory requirements, specifically where there is a local legal requirement to provide information to government/regulatory authorities;
  
• to monitor (on an aggregated basis) the number of individuals entering and working in a Shell premise for human resources and real estate planning; and
  
• in the case of contractors only (not Shell employees) the date and time of their entry and exit of Shell premises is used for the purposes of financial management and control.
  

Most of our premises and assets are equipped with surveillance cameras (CCTV). Where surveillance cameras are used they will be identified. Surveillance cameras are used for health, safety and security specifically the protection of Shell assets, Shell staff and visitors to Shell premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or actual criminal activity, in which case they may be viewed by internal Shell investigation teams and externally if legally required or permitted by law enforcement or other government authority.

Screening

In order 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, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available or government issued sanctions lists and is compared with information held about you by Shell (for example from the Conflict of Interest register - see here for more information).

Any personal data collected through the screening will not involve profiling or automated decision making regarding suitability for continued employment, internship or engagement as a contractor.

Who is responsible for any personal data collected?

Shell (China) Limited (30/F Unit 01-02, No. 16 Building, No. 1 Courtyard, Jian Guo Men Wai Avenue, Chaoyang District, Beijing, 100004, People’s Republic of China), and / or your employing company within the Shell group of companies (or in the case of dependents, the employing company of the Shell employee) will be responsible for processing your personal data (including that of dependents).

In the case of individual contractors, the company within the Shell group that has contracted your services solely or jointly with its affiliates within the Shell group of companies and your external contracting/employing company/agency.

Who do we share your personal data with?

Who will we share the personal data with?

Your personal data are exclusively processed for the purposes referred to above 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;
• Authorized third party agents, service providers, external auditors and/or subcontractors of Shell; and
• 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 law; or
• Any person to whom Shell proposes to transfer any of its rights and/or duties.

If required by applicable laws, we will notify you and seek your separate consent when we share your personal data with other personal data controller.

Your personal data may be transferred outside of your country, subject to appropriate safeguards.

Transfers of your personal data to other countries

To fulfill the purpose of handling your personal data as described in this Privacy Notice, as the HR operational service is provided by HR Operations team overseas and the personal data is stored and maintained in overseas system, your personal data referred to in this Privacy Notice may need to be transferred to Shell International B.V. (Carel van Bylandtlaan 16, 2596 HR Den Haag, the Netherlands; Trade register no.: 27155369) and / or other company/ies within Shell group of companies. (Please see Appendix 1 for the company list of overseas data receivers within Shell Group that receives your personal data.)

Where your personal data have been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include signing Standard Contract Clauses on personal information export with overseas data receivers, Binding Corporate Rules for transfers among the Shell group and for Shell companies in the EU, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at www.shell.com.cn/en_cn/privacy.html or by contacting privacy-office-SI@shell.com.

As required by applicable laws and regulations, the details of sharing your personal data with overseas data receivers are provided in Appendix 1.

Shell is committed to safeguarding your personal data.

Security of your personal data

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.

Shell only holds your personal data for a defined period of time.

How long do we hold your personal data for?

All information, including personal data, is managed in line with the Shell group standards for Information and Records Management and securely handled (including deletion, or when it is technically difficult to delete personal data, Shell will cease the processing of the personal data, except for the storage and any necessary measure taken for security protection) once no longer required for a legitimate business purpose or for a legal/regulatory purpose.

With some exceptions required to comply with local legal requirements:

• information contained within personnel files is held for no longer than 30 years once your employment has terminated;
• information relating to your compensation and benefits are held for no longer than 99 years from the commencement of employment;
• any personal data gathered as part of the screening against publicly available or government issued sanctions lists and media sources are held for no longer than 15 years after they were first gathered;
• the names, date, time and access points for all individuals entering Shell premises are held for 3 years from each access;
• other records and materials generated due to performance of your employment relationship, where an individual has been dismissed or had their contract terminated due to serious misconduct, including breaching the Shell Life Saving Rules or breaching the Shell Code of Conduct, that information is held for up to 30 years post termination.

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 you object to the processing of the personal data and there is no longer a legitimate purpose to retain it.

Your rights and how to exercise them.

Your rights in relation to your personal data

We aim to keep our information about you as accurate as possible. You can request:

• access to your personal data;
• correction or deletion of your personal data (but only where they are no longer required for a legitimate business purpose);
• that the processing of your personal data is restricted or you withdraw your consent to process your personal data (when consent is legally required for data processing); and/or
• that you receive personal data that you have provided to Shell, in a structured, digital form to be transmitted to another party, if this is technically feasible.

For those individuals who have access to HR Online you can access your personal data through: https://shellhrservices.my.site.com/HROnlineEC/s/.

Alternatively, please contact HR Operations. If you are a contractor you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact privacy-office-SI@shell.com.

Who can you contact if you have a query, concern or complaint about your personal data?

You can first contact HR Operations. If you are a contractor you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact privacy-office-SI@shell.com.

If you have further issues, queries or complaints regarding the processing of your personal data please contact Privacy-Office-SI@shell.com.

You may also contact the Shell Group Chief Privacy Officer at Shell International B.V. (Trade Register, No. 27155369 Correspondence: Carel van Bylandtlaan 16, 2596 HR Den Haag, The Netherlands) and/or other company/ies within Shell group of companies.

If you are unsatisfied with the handling of your personal data by Shell, then you have the right to lodge a complaint to the relevant government authorities including Cyberspace Administration of China, or the Dutch Data Protection Authority whose address is Autoriteit Persoonsgegevens, PO Box 93374, 2509 AJ The Hague, The Netherlands. Please visit http://www.cac.gov.cn/ or https://autoriteitpersoonsgegevens.nl/en for more information.

This Privacy Notice is updated over time.

Changes to this Privacy Notice

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in June 2023.