JLL Supplemental Privacy Statement for Employee/ Candidate in China
Effective date: December 2023
To fulfil the requirements of the applicable personal information privacy laws in the People’s Republic of China (“China”) including the Personal Information Protection Law of China (“PIPL”), the following supplemental statement is released. For more information about how we process information please view our Employee/ Candidate Privacy Statement .
With respect to the handling activities of personal information of candidates and employees in China, if there is any conflict between this JLL Supplemental Privacy Statement for Employee/ Candidate in China and JLL's Employee/ Candidate Privacy Statement, this JLL Supplemental Privacy Statement for Employee/ Candidate in China shall prevail; and if there is any conflict between JLL’s Employee/ Candidate Privacy Statement and the laws and regulations of the People's Republic of China, the laws and regulations of the People's Republic of China shall prevail.
1. JLL's legal basis for collecting and using your personal information
JLL collects and uses your personal information on the following legal bases:
1.1. With your consent;
1.2. Necessary for the conclusion and performance of a contract to which you are a party, or necessary for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract signed in accordance with the law;
1.3. Necessary for the performance of statutory duties or obligations;
1.4. It is necessary to respond to public health emergencies or to protect the life, health and property safety of natural persons in an emergency;
1.5. Collect and use your personal information within a reasonable scope for the public interest, such as news reporting and public opinion supervision;
1.6. In accordance with applicable laws and regulations, process your personal information that you have disclosed or that has been legally disclosed within a reasonable scope;
1.7 Other circumstances provided for by laws and administrative regulations.
2. How JLL collects and uses your personal information
2.1. If you are a candidate, for the purpose of contacting you, assessing your suitability for the recruitment position, facilitating the recruitment process, and providing services, JLL needs to collect and process the following personal information from you through electronic means for achieving the aforementioned purposes.
a. Basic personal information: including last name-Chinese, first name-Chinese, last name-English, first name-English, common name, province/city, postal code, email address, phone number, phone number extension, landline or mobile phone number, WeChat ID and preferred name;
b. Employment and educational history information: including job title, company, company location, department name, years of experience, description of duties, school, degree, major, grades, years of attendance, description of educational experience;
c. Project, Skills and personal networking information: including project name, project duration, company name, project description, language, language fluency, skills, award name, award duration, certificate name, personal web site cover, personal web site, personal web site description, salary expectations, resume attachments;
2.2. If you are an employee, JLL needs to collect and process the following personal information of its employees through written and electronic means for the purposes of entering into and fulfilling the employment/ labor contracts with its employees, conducting compliance audit, carrying out human resource management, and for the safety and security of its employees in case of emergencies.
a. Basic personal information: including last name-Chinese, first name-Chinese, last name-English, first name-English, common name, province/city, postal code, email address, phone number, extension, landline or mobile phone number, WeChat ID and preferred name;
b. Employment and educational history information: including job title, company, company location, department name, years of experience, description of duties, school, degree, major, grades, years of attendance, description of educational experience.
c. Project, skills and personal networking information: including project name, project duration, company name, project description, language, language fluency, skills, award name, award duration, certificate name, personal web site cover, personal web site, personal web site description, salary expectations, resume attachments.
d. Employee basic information and job information: including last name-Chinese, first name-Chinese, first name-pinyin or western characters, last name-pinyin or western characters, effective date, country/ region, job title, personal photo, date of birth, age, citizenship, personal name, employee ID, supervisory organization, position, position summary, position title, manager, personal phone number, email address;
e. Employee family and work contact information: address-local text, personal phone number type, personal phone number country/ area code, personal phone number, personal phone number extension, personal phone number visibility, email address, work phone number type, work phone number, work phone number country/ area code, work phone number extension, work phone number visibility.
f. Contact Information: Emergency Contact information: legal name, relationship, preferred language, usual address, usual phone number; Beneficiary contact information: legal name, relationship, date of birth, gender;
g. Managing information required for employee workplace and employment, including the collection of location and network data.
h. Other personal information that the employee provides or discloses to the Company.
2.3. If you are an employee, JLL needs to collect and process the following sensitive personal information of its employees through written and electronic means for the purposes of entering into and fulfilling the employment/ labor contracts with its employees, implementing human resource management, and providing employee benefits.
a. for the purpose of office security management, attendance management, work record management, etc., the Company needs to use biometrics equipment or systems and process the relevant biometric information of the employee, including fingerprints and face recognition.
b. for the purpose of sick leave management, field and travel management, maternity leave management, labor discipline management and other needs, the Company needs to process the medical and health information of the employee, including documents supporting leave of absence, relevant medical records, hospitalization records, maternity information, relevant medical history, signatures, transaction details, expense receipts and tax records.
c. for the purpose of payroll management, financial reimbursement, commercial insurance benefits addition, etc., the Company needs to process the payroll and financial account information of the employee, including compensation package, pay grade, total salary and allowances, pay grade summary, company, pay plan details, account alias, country/region, bank name, bank branch name, account type, account number, account holder’s name;
d. for the purpose of office security management, company attendance management, labor discipline management, and employee management under special circumstances, the Company needs to process the location and tracking information of employees, including accommodation information, tracking, and vaccination status.
e. for the purpose of entering into and performing the contracts to which the employee is a party, maintaining senior management information, purchasing mandatory social security and provident fund, tax declaration and other day-to-day governmental affairs necessary for processing, the company needs to process other personal sensitive information of the employee, including resident identity documents, passport, visa country/region, type of the visa resident identity document, visa current identification number, the date of the visa issuance, marital status and date of marital status;
f. for the purpose of insurance purchases, benefits, and vacation arrangements, the Company needs to process the employee’s dependent information (including children under the age of 14 years), including legal name, gender, date of birth, citizenship, full-time student, date of beginning of full-time student status, date of ending of full-time student status, relationship, usual address, usual phone number, usual e-mail address, usual web address, state-issued documents, government-issued documents, and other documents;
If the employee does not agree to the use of sensitive personal information for the above purposes, JLL will not be able to implement the above human resource management and provide corresponding employee benefits. Since the leakage or illegal use of the employee’s sensitive personal information may easily lead to the infringement of the human dignity or jeopardize the personal and property safety, JLL will take appropriate measures to protect the security of employee’s personal information and minimize the adverse impact on their personal rights and interests.
3. Your rights in your personal information processing activities
In addition to the rights listed in JLL’s privacy statement, you also have the following rights:
3.1. The right to know, the right to decide, and the right to restrict or refuse others to process your personal information
You have the right to know and decide on the processing of your personal information, and have the right to restrict or refuse the processing of your personal information by others; except as otherwise provided by laws and administrative regulations. In certain circumstances, you can request JLL to suspend the processing of your personal information. For example, if you question the accuracy of the information or have concerns about how JLL is handling your data. In most cases, JLL will implement restrictive measures for a certain period of time while verifying the accuracy of your personal information or reviewing the legal basis for information processing.
3.2. Request data transfer
You can request the transfer of your personal information to the personal information processor designated by you, and JLL will provide a way to transfer it if the conditions stipulated by Cyberspace Administration of China are met.
3.3. Explain the rules for processing personal information
You have the right to request us to explain the rules for processing personal information.
You can exercise your rights regarding personal information processing activities by contacting JLL through the contact details set out in JLL’s privacy statement.
JLL will respond to your request within the timeframe required by law. If the situation involved is complex and requires longer processing, JLL will also inform you in a timely manner.
If the request to exercise your rights in the processing of personal information cannot be realized, JLL will explain the reasons.
4. Cross-border Data Transfer ("CBDT”)
4.1. Due to the global nature of JLL's business, JLL may transfer your personal information outside of China (“cross-border data transfer”) by renting a dedicated line with an operator or the public Internet. The overseas recipient is Jones Lang LaSalle Incorporated, the parent company of JLL in Maryland, USA, details are as follow:
Name of overseas recipient | Jones Lang LaSalle Incorporated |
Types of personal information | The personal information as set out in a, b and c of Article 2.1 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China |
The information types as set out in a, b, c, d, e, f and g of Article 2.2 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China | |
The leave supporting documents as set out in b of Article 2.3 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China | |
The information types as set out in c, e, and f of Article 2.3 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China | |
Purpose of processing personal information | The purposes set forth in Article 2.1 and 2.2 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China |
The purposes set forth in b, c, e, f of Article 2.3 of this JLL Supplemental Privacy Statement for Employee/ Candidate in China | |
Processing method | Viewing, business approval, analysis under authorization management |
Contact details | Phone number: +1(312)7825800 Address: 7, St. Paul Street, Baltimore, Maryland, 21202, U.S.A. |
4.2. The overseas recipient will retain your personal information in accordance with the necessary requirements to achieve the aforementioned purposes and applicable laws and regulations, as follows:
The retention period for your personal information is specified in JLL's Retention Schedule. After receiving your personal information, the Overseas Recipient will retain it for the duration specified in the Retention Schedule.
Upon expiration of the retention period, your personal information will be deleted or anonymized. If it is technically difficult to delete your personal information, it will only be stored and subject to necessary security measures, without further processing or use for other purposes.
4.3. JLL will delete your personal information in the following circumstances, and you also have the right to request the deletion of your personal information by contacting PrivacyEnquiries@jll.com: (1) the purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve; (2) JLL ceases to provide products or services, or the retention period has expired; (3) you withdraw your consent; (4) JLL violates laws, regulations, or agreements in the processing of your personal information; (5) other circumstances as provided by laws and regulations. If the retention period specified by laws and regulations has not expired, or if it is technically difficult to delete your personal information, JLL will cease processing, except for storage and necessary security measures.
4.4. JLL complies with the Personal Information Protection Law of the People’s Republics of China and the Privacy Statement of JLL when transferring the personal information of the employee outside of China. If you have any questions about JLL’s provision of your personal information outside of China, or wish to exercise your rights in personal information processing activities, please contact PrivacyEnquiries@jll.com.
JLL will retain the above personal information in accordance with the retention period stipulated in the Retention Schedule of Jones Lang LaSalle Group. Upon expiration of the retention period, JLL will promptly delete or anonymize your personal information. If the technical feasibility of deleting your personal information is challenging, JLL will only store it and apply necessary security measures. JLL will not further process or use the personal information of candidates for any other purposes.
To exercise the rights described in the privacy statement and/or any other applicable rights related to personal information, or for inquiries regarding privacy-related matters, please contact JLL through privacy-related questions online form, or email PrivacyEnquiries@jll.com. JLL will respond to your request within the timeframe required by law. If the situation involved is complex and requires longer processing, JLL will also inform you in a timely manner.
If you are not satisfied with our response, you may contact the department responsible for protecting personal information in your region to make a complaint.