Swire Hotels PERSONAL INFORMATION COLLECTION STATEMENT for employees, workers, consultants, contractors and interview candidates
Version 2: 21 October 2020
This Personal Information Collection Statement ("PICS") applies to all employees, temporary workers, consultants, independent contractors of Swire Hotels relevant legal entity (please refer to Appendix below for the list of entities collecting relevant personal data) and any other persons working for or in connection with business of Swire Properties Hotel Holdings Limited and its subsidiaries and relevant associated companies (“Swire Hotels”), and any reference to "employment" or "engagement" in this PICS refers to the relationship that such persons have with Swire Hotels or Swire Hotels relevant legal entity, and any persons who are applying for aforementioned jobs or positions.
Please read this PICS to understand your rights and the choices you can make about the way how your Personal Data is collected, transferred or disclosed by us.
Throughout your employment by, engagement with, secondment to or application to work in Swire Hotels relevant legal entity, Personal Data will be collected in relation to you for purposes related to your employment or engagement as specified hereinbelow. It is also necessary for you to supply to us with Personal Data about yourself and sometimes also your family members from time to time in connection with your employment and engagement. You represent and warrant that the consent of your family members whose Personal Data you have provided and disclosed to us have been sufficiently obtained to allow us to process the same in relation to the purposes stated herein.
Purpose of Collection
The purposes for which such Personal Data may be used will include the following:
- Recruitment and selection;
- Fulfilment of the statutory and legal obligations of Swire Hotels, including compliance with any request from any governmental or regulatory authority or court order (in any jurisdiction);
- Administration and management of personnel, including determining and reviewing salaries, bonuses and other benefits for you and your eligible dependant(s), if any;
- Administration of individual records during the course of employment or engagement;
- Manpower planning, training and development, including secondment and transfer;
- To introduce and/or cross-refer you to any of the divisions, subsidiaries, associated, affiliated companies and/or other business units within John Swire & Sons (H.K.) Ltd., local or overseas, for which we may or may not be remunerated;
- Career and performance development, including consideration for promotion;
- Provision of personal reference or reference for any personnel related activities;
- Disciplinary purposes arising from the conduct of personnel or their ability to perform services for Swire Hotels relevant legal entity properly;
- Administration of Swire Hotels' business, including making tax returns and/or other related filings with government authorities, whether locally or overseas;
- Corporate restructuring, reorganization, transfer, assignment of all or part of Swire Hotels or its businesses, or such similar purposes;
- Health care and ensuring appropriate and safe working environment;
- Communication between Swire Hotels and its personnel, and between Swire Hotels and their family members in relation to death, illness, injury or emergency in connection with work;
- Legal proceedings (including prospective legal proceedings) and obtaining legal advice, whether locally or overseas;
- Establishing, exercising or defending legal rights, whether locally or overseas;
- Promotion or marketing of Swire Hotels' business whether locally or overseas via various media, including but not limited to newspapers, magazines, Swire Hotels' website and social media platforms;
- Monitoring compliance with internal rules and policies of Swire Hotels;
- Compliance with applicable procedures, laws and regulations, whether locally or overseas; and
- Purposes directly relating thereto.
It is obligatory that you provide any Personal Data requested from you, unless you are informed otherwise on or before collection by Swire Hotels relevant legal entity. Failure to supply such Personal Data may result in Swire Hotels relevant legal entity being unable to carry out its human resources management functions including (but not limited to) provision of benefits or otherwise the management of Swire Hotels' affairs. Swire Hotels will take all practicable steps to ensure that Personal Data collected and held by Swire Hotels are protected against unauthorized or accidental access, processing, erasure or other use.
Classes of Transferees
Swire Hotels relevant legal entity may nonetheless use or disclose Personal Data in accordance with the relevant law from time to time. Swire Hotels relevant legal entity may provide Personal Data to the following parties, whether locally or overseas, for the above-mentioned purposes for which the Personal Data is to be used (or a directly related purpose) as follows:
- Appropriate and authorized persons within Swire Properties Limited and its affiliate and/or subsidiary companies;
- Swire Properties Limited and its affiliate and/or subsidiary companies, local or overseas;
- Senior executives of existing or potential business partners of Swire Hotels and Swire Properties Limited;
- Any joint venture of Swire Properties Hotel Management Limited, Swire Hotels relevant legal entities and Swire Properties Limited and their affiliate and/or subsidiary companies;
- John Swire & Sons (H.K.) Limited in their capacity as the parent company of Swire Hotels for the following purposes
- Salary, bonus and remuneration review and approval by John Swire & Sons (H.K.) Limited
- Talent review for human resources plan and management including succession plans by John Swire & Sons (H.K.) Limited
- Records for qualification, certification and/or training for professional qualified persons
- Manpower planning, training and development, including secondment and transfer
- Special circumstances involving protection of your vital interest or public health interest such as COVID-19
- Any of the divisions, subsidiaries, associated, affiliated companies and/or other business units within John Swire & Sons (H.K.) Ltd., local or overseas, for cross referral of transfer, assignment and secondment
- Any relevant government or regulatory authorities, including but not limited to, the tax department, the labour department and the immigration or custom department;
- Persons seeking employee references;
- Any of our auditors, legal and/or other professional advisors or any other person under a duty of confidentiality to us;
- Any subsidiary/affiliated companies or service providers, local or overseas, for matters related to career planning/development within Swire Hotels relevant legal entity;
- Third parties in connection with any corporate restructuring, reorganization, transfer, assignment or sale of all or part of Swire Hotels or its businesses, or such similar purposes;
- Third parties for promotional or marketing purposes, including but not limited to advertising and PR agencies;
- All relevant third parties in connection with the operation of Swire Hotels' business, including but not limited to any actual or proposed bidder, tenderer, service provider, downstream sub-contractor(s), business partner or any other person who provides/ introduces services to us or to whom we provide introductions or referrals.
Access to Personal Data
You may have the right to:
- check whether Swire Hotels relevant legal entity holds any Personal Data about you;
- request access to such Personal Data in accordance with relevant legal requirement;
- request Swire Hotels relevant legal entity to correct any Personal Data relating to you which is inaccurate in accordance with the relevant legal requirement; and
- ascertain Swire Hotels' policies and practices in relation to Personal Data and be informed of the types of Personal Data held by Swire Hotels relevant legal entity.
In accordance with the relevant legal requirement, Swire Hotels may have the right to charge a reasonable fee for the processing of any Personal Data access request. In determining a reasonable charge for handling such requests, the cost of actual time spent by administrator(s) / manager(s) who are involved in processing a particular Personal Data access request is the basic element of the fee charged. In addition, cost of copying per sheet of paper will also be charged.
Security of Personal Data
In order to ensure the correct use and to maintain the accuracy of Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various physical, electronic and management measures to safeguard and secure the Personal Data we collect.
For the Personal Data we collect online, we use an industry standard for encryption over the Internet, to protect the Personal Data.
The Personal Data you provide to us will be stored in a database for no longer than is necessary. The website has a firewall in place, which should protect the Personal Data collected from you against unauthorised or accidental access. However, complete confidentiality and security is not yet possible over the Internet, and privacy cannot be completely assured in your communications to us. You acknowledge that personal information is disclosed at your own risk, and may be subject to unauthorised use by others. This may result in, among others, you receiving unsolicited messages from other parties. We are not responsible in any manner for direct, indirect, special or consequential damages, howsoever caused arising out of the communication of information to us. You are encouraged to protect against unauthorised access to your password. Make sure you sign out from your account when finished particularly when using a shared computer.
All requests for a list of our subsidiaries/associated/affiliated companies, or access to Personal Data, or correction of Personal Data, or for information regarding policies and practices and types of Personal Data held, should be addressed to the Data Protection Officer in Swire Hotels at the following address:
The Data Protection Officer
Suite 2701-05, Cityplaza One
1111 King’s Road
Taikoo Shing, Hong Kong
Appendix: Swire Hotels relevant legal entities
Update date: 3 September 2020
Swire Properties Hotel Holdings Limited
Swire Properties Hotel Services Limited
Airline Hotel Limited
Chengdu Qianhao Real Estate Company Limited The Temple House Hotel Management Branch Office
Guan Feng (Shanghai) Real Estate Development Company Limited The Middle House
Beijing Linlian Real Estate Company Limited East Hotel
Beijing Sanlitun Hotel Management Company Limited
BCC Hospitality Services LLC