Privacy Notice - Shell Group Recruitment

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

What does this Privacy Notice cover?

This Privacy Notice provides information about personal data which are processed by a company or companies within the Shell group of companies (‘Shell’ or ‘we’) in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with Shell. This includes prospective employees, interns and contractors.

For individuals who are successful in their application for employment, internship or engagement as a contractor, the Privacy Notice - Shell Group Employee, Contractor and Dependents’ Personal Data available at https://www.shell.com.cn/en_cn/privacy/ex-employee-notice.html will apply.

As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how Shell is processing your personal data. In those instances, such privacy notices will be communicated to you separately.

This Privacy Notice explains what personal data we process 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.

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 its affiliates within the Shell goup of companies that contact you for employment or engagement as the case maybe, is responsible for processing your personal data.

If personal data of children is gathered this requires consent of the parent or guardian.

Special Notice - if you are under 16 years old and wish to apply for a Shell sponsored education or innovation event

Except in those cases where Shell organizes educational events specifically designed for children, we do not intentionally collect personal data of individuals under 16 years old. If you are under 16 years old please do not send us your personal data for example, your name, address and email address. If you wish to contact Shell in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.

The categories of personal data we collect about you.

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

We process personal information relating to individuals who apply to work for, or who attend a recruitment event and/or undertake an assessment (‘Applicants’).

This includes personal name, identity card number, phone number, resident address, date of birth, whether you have the legal right to work in the country in which you have applied, your application for employment, your qualifications and experience, results of interviews and assessments, personal data which has been published by you or published lawfully, and other personal data needed for recruitment purpose.

Sensitive personal data

For the purposes of recruitment, with your separate consent (if required by law), special categories of data (‘sensitive personal data’) including personal ID card, personal data regarding health data may be processed only as strictly required for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems or for the establishment, exercise or defense of claims.

In addition, in order to ensure equal employment opportunities, we may also gather additional sensitive personal data regarding Applicants, including their nationality, racial and/or ethnic origin.

The purposes for which we process your personal data.

For what purposes do we process your personal data?

We process your personal data for the following purposes:

  • Human Resources, personnel management, business process execution and internal management - including resource planning, and recruitment;
  • Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of Shell’s assets and staff, authentication of individual status and access rights;
  • Legal and/or regulatory compliance - including compliance with legal or regulatory requirements; or
  • Management reporting and analysis - including statistical analysis and surveys regarding the quality of the recruitment process.

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.

Pre-screening of Applicants

We carry out screening of all Applicants who we intend to make an offer of employment, engagement or internship (as the case may be) and prior to any offer being confirmed for the purposes of:

  • verifying the information that an Applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No steps will be taken in this respect until the Applicant confirms the verification can take place;
  • screening Applicants against publicly available or government issued sanctions lists and media sources. This is 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.

Automated decision making and profiling

All applicants must answer questions which are necessary to ensure that individuals can lawfully enter into a contract with a Shell company if they are successful in their application. In addition, for graduate hires, we utilize an online assessment tool which scores individuals on their suitability for employment, based on automated decision making to ensure objectivity. In those cases, you will be notified of this and you will have the opportunity to have such automated decisions reviewed and explained by or on behalf of a member of the Shell recruitment team. Save for graduate hires or as specifically notified to you in a bespoke privacy notice or a supplementary privacy statement during the recruitment process, no profiling or automated decision making will take place to determine suitability or eligibility for employment or engagement as a contractor.

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

Why do we process your personal data?

We only process personal data of Applicants:

  • where it is necessary to enter into a contract with the Applicants;
  • where it is necessary to comply with a legal obligation;
  • 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
  • (only if legally required) with the explicit consent of the Applicant.

In those cases where processing is based on consent, 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.

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 in particular authorised third parties who carry out reference and background checks on behalf of Shell;
  • 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.

Interacting with Shell through social media

If you choose to interact with Shell through social media on a Shell administered social media page (‘Shell Social Media Page’) such as Wechat, Weibo or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in Shell) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to Shell. You can delete any data that you shared on these sites at any time through your relevant social media platform’s account. Shell does not track your activity across the different social media sites that you use. If you send a message to Shell via any messanger service on a social media platform, these messages are held for no longer than one month after receipt. Please contact Shell if you wish to make a request that you are unable to action yourself and which relates to a Shell Social Media Page - see the section below.

Additionally and to the extent Shell is jointly responsible with a social media platform of a Shell Social Media Page, Shell will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Shell Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.

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. (Correspondence: 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 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 https://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 you hold my personal data for?

Subject to different retention periods set out in the privacy notice in your location, we hold personal data of unsuccessful Applicants for at least six (6) months but no longer than three (3) years after the recruitment process or assessment has been completed.

If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Privacy Notice - Shell Group Employee, Contractor and Dependents’ Personal Data, which is available at https://www.shell.com.cn/en_cn/privacy/ex-employee-notice.html and from the website in your location.

What are the consequences of not providing your data?

Personal data requested and provided by Applicants are required in order to fulfil legal requirements and/or which is required for entering into a contract with you (or in the case of a contractor your employer/service provider). Failure to provide us with the information requested which is limited to that required for these purposes will negatively affect your chances of being selected for any potential employment, engagement or internship.

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);
  • to explain the decision made by automatic decision-making tools or to refuse such decision if made solely based on the automatic decision making tools.
  • 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.

To make any of these requests, please contact careers@shell.com.

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

You can first contact our local recruitment team at careers@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. (Correspondence: Carel van Bylandtlaan 16, 2596 HR Den Haag, The Netherlands; Trade Register, No. 27155369).

If you are unsatisfied with the handling of your personal data by Shell, then you have the right to lodge a complaint to 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.

Special Notice - For any technical issue with regards to your recruitment process or in case of questions or comments regarding job opportunities at Shell, please contact us at: Shell Careers SSSCMLA-HRVO/N-T1 careers@shell.com.

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Shell may use cookies and similar technologies that aim to collect and store information when you visit a Shell website. This is to enable Shell to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the Shell cookies preference tool on Shell websites - for more information, please refer to the Shell Cookie Policy at http://www.shell.com.cn/en_cn/cookie-policy.html.

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.

Appendix 1: Details about Sharing Personal Data with Overseas Data Receivers

As the personal data subject, you have the right to contact us to obtain details about personal data sharing with overseas data receivers and exercise your rights.

Domestic personal data controllers that transfer personal data overseas Shell (China) Limited
Shell Energy (China) Limited
Shell (China) Exploration and Production Co. Ltd
Shell (Zhejiang) Petroleum Trading Co. Ltd
Overseas data receivers Shell Information Technology International B.V.
Shell International B.V.
Shell International Petroleum Company Limited
Shell International Exploration and Production B.V.
Shell International Trading and Shipping Company Limited
Transfer purpose

We transfer your personal data collected under this Privacy Notice to the above-mentioned overseas data receivers only for the following purposes:

  • where it is necessary to enter into a contract with the Applicants;
  • where it is necessary to comply with a legal obligation;
  • 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
  • (only if legally required) with the explicit consent of the Applicant.
Scope of personal data transferred overseas

We will only transfer the personal data collected under this Privacy Notice to the above-mentioned overseas data receivers:

  • personal name, identity card number, phone number, resident address, date of birth, whether you have the legal right to work in the country in which you have applied, your application for employment, your qualifications and experience, results of interviews and assessments, personal data which has been published by you or published lawfully, and
  • other personal data needed for recruitment purpose.
Scope of sensitive personal data transferred overseas

We will only transfer the sensitive personal data collected under this Privacy Notice to the above-mentioned overseas data receivers:

  • personal ID card, personal data regarding health data may be processed only as strictly required for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems or for the establishment, exercise or defense of claims.

(Above-mentioned sensitive personal information is identified according to Personal Information Protection Law)

Third-party vendors that receive the personal data re-transferred by overseas data receivers
  1. T-Systems
  2. Wipro
  3. Accenture
  4. Salesforce
Method of transfer System transformation
Retention period of exported personal data
We hold personal data of unsuccessful Applicants for at least six (6) months but no longer than three (3) years after the recruitment process or assessment has been completed.
Overseas storage location Ireland, Dutch, German and France