Privacy Notice

GSK Candidate Privacy Notice

China (Mainland)

 

Last Updated: June 29, 2023

This Privacy Notice is intended for recruitment candidates.

Thank you for your interest in GlaxoSmithKline. We understand that privacy is important to you. We are committed to treating your personal information with care and integrity.

Our Privacy Notice tells you what personal information we collect and how we collect it. We explain what we use your personal information for during recruitment and pre-employment screening. We also explain how we protect your personal information and keep it safe.

GlaxoSmithKline values your privacy. When we say “GSK”, “we”, “us” or “our”, we mean GlaxoSmithKline(China) Investment Co., Ltd. (at Unit 901, 9th Floor, Building 56, East 4th Ring Middle Road, Chaoyang District, Beijing) and its affiliated companies.

For candidates based outside of China, the following applies:

Personal information means any information or piece of information which could identify you either directly (e.g. your name) or indirectly (e.g. a unique ID number).

For candidates based in China, the following applies:

Personal information refers to various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding anonymized information; “process(ing)” personal information refers to collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. of personal information.

Sensitive personal information refers to the personal information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used, including such information as biometric identification, religious belief, specific identity, medical health, financial account and whereabouts and tracks, as well as the personal information of minors under the age of 14.

If anything in this Privacy Notice conflicts with local law in your jurisdiction, local law prevails.

In this Privacy Notice, we explain:

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What personal information we collect about you?

Note: For candidates based in China, the bold underlined personal information is sensitive personal information defined by China PIPL.

As part of our recruitment and pre-employment screening, we collect your:

  • Basic information – your name (including prefix or title), gender, age or date of birth. For candidates based in China, we may also collect your WeChat Open ID and location.
  • Contact information – information you provide to us that allows us to contact you, e.g. your personal or business email, mailing address, address, telephone number, and profile on a professional social media platform;
  • Signature information – For candidates based in China, we also collect your signature handwriting or digital electronic signature;
  • Professional information and experience – information related to your education, work experience, references, referees, and CV;
  • National identifiers – your national ID/passport, residency and work permit status, social security number, or other taxpayer/government identification number;
  • Financial information – your salary, retirement account information, company allowances, bonus, benefits, working time records, and taxpayer reference number (e.g., Tax Identification Number, National Insurance number, Social Security Number). We will also collect your reimbursement records and bank details (such as bank account number) if we reimburse you for expenses during the recruitment process;
  • Dependents' information – For candidates based outside of China, we may collect information related to your dependents, e.g., the first and last names, dates of birth, and contact details of your spouse/partner and dependents;
  • Information collected during interviews – comments noted by our interviewers and audio/video recordings of the interview (in case of telephone interviews or video-enabled interviews);
  • Background information – education and academic as well as professional qualifications. If we want to offer you the job, we may need to complete pre-employment screening. We may then also collect additional background information such as credit history, criminal records and occupational health information (if permitted by law); and
  • Special categories of personal information – information related to your racial or ethnic origin, trade union membership, veteran status or information about your health and disabilities. We use this information to make sure we meet relevant laws. For candidates based outside of China, if applicable, we may also collect information related to your religious, political or philosophical beliefs, or sexual orientation. If we offer you employment, we may also ask you for information about your health (physical or mental) so we can give health and insurance benefits to you and your dependents. We will also use this information to discuss with you what reasonable adjustments we can make for you. We want to make sure we provide an inclusive workplace.

You can decide whether to give us special categories of information, if we ask you for them. If you decide not to share these with us, please be assured this does not affect your application.

You can also choose not to give us the other types of personal information when we ask you for them. If you decide not to give us your personal information, we may not be able to assess or consider your application.

If you give us the personal information of another person, e.g., your spouse/partner or referees, we assume you have their permission to share their data with us.

We will not process personal information (including any of the information listed above) if the law of your country prohibits us to do so.

How do we collect your personal information?

Directly from you when you:

  • Create an account and profile in the GSK careers portal;
  • Share or use your social media profile to access the GSK careers portal;
  • Sign up with us to receive open job postings;
  • Share your resumé with us, either via the GSK careers portal or through other means; and
  • Take part in meetings, interviews or recruitment exercises.

From other sources:

  • Recruitment agencies;
  • Companies who do pre-employment screening for us; and
  • Your colleagues and/or managers when they give us your reference.

From public sources:

  • We collect your personal information from public sources, if allowed by law. We may use such a source to verify your licenses, or to complete any checks we need to do in order to meet relevant laws.

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How do we process your personal information?

We will only use your personal information for the purposes we have described below in this Privacy Notice, or for purposes which are reasonably compatible to the ones described. We cannot, and will not, use it for other purposes without your permission, unless we have a legal right or obligation to do so.

To consider your application.

We will use your personal information:

For candidates based in China, we will process your basic information, contact information, professional information and experience, financial information and information collected during interviews based on the following purposes:

  • To reply to your application. If someone else referred you to us or we obtained your information from other sources, we will use your personal information to contact you and let you know about our recruitment process;
  • To create a profile of you;
  • To assess how suitable your profile is for the job you are applying for;
  • When we evaluate all our candidates and create a shortlist; and
  • To conduct interviews and exercises during the recruitment process.

For candidates based in China, we will also use your information to:

  • Reimburse you for your expenses in the recruitment process.

For pre-employment screening, if we decide to offer you employment.

We will use your personal information to:

For candidates based in China, we will process your basic information, contact information, signature information, professional information and experience, personal identity information, financial information, background information and special categories of personal information based on the following purposes:

  • Check your background, references and other information you gave us, to the extent allowed by law. We share your personal information with companies who do these pre-employment screening checks for us; and
  • Prepare an offer of employment and other documents we use at this pre-contract stage of our recruitment process.

To include you in GSK’s talent pool.

We will use your personal information to:

For candidates based in China, we will process your basic information, contact information, professional information and experience and information collected during interviews based on the following purposes:

  • Consider you for opportunities we have now, or future ones, in any of the GSK companies and affiliates. This means we will share your information with other GSK entities; and
  • Let you know about opportunities or to ask you to update your profile.

To manage and improve our recruitment processes as well as our business operations related to the recruitment process.

We will use your personal information to:

For candidates based in China, we will process your basic information, contact information, professional information and experience and information collected during interviews based on the following purposes:

  • Manage our network and information systems security;
  • Keep records related to our hiring processes;
  • Measure the recruitment process against our aspirations to ensure we are adhering to fair employment practices; and
  • Prepare and perform management reporting and analysis, including analytics and metrics, related to the recruitment process.

To achieve other purposes.

We will use your personal information:

For candidates based in China, we will process your basic information, contact information, signature information, professional information and experience, personal identity information, financial information, dependents’ information, information collected during interviews, background information and special categories of personal information based on the following purposes:

  • To follow applicable laws and regulations;
  • To respond to requests from competent public authorities;
  • To tell you about changes to our terms, conditions and policies;
  • To exercise or defend GSK against potential, threatened or actual litigation;
  • To protect GSK, your vital interests, or those of another person;
  • To provide work related accommodations or health and insurance benefits to you and to your dependents;
  • To evaluate GSK's progress in achieving its diversity hiring goals to ensure equal opportunity monitoring and reporting.
  • To respond to and handle your queries or requests; and
  • When we sell, assign or transfer all or part of our business; 

Why are we allowed to process your personal information?

For candidates based outside of China, we can process your personal information when one of the following applies:

  • To take steps before entering an employment contract or perform an employment contract;
  • To follow the law, for example, employment, social security and occupational health laws and regulations;
  • You have specifically given us your permission when such permission is obligatory (the law calls it “consent”). You can withdraw your permission at any time;
  • It is in our interest in considering you as a candidate for current and future employment opportunities (the law calls it “legitimate interest”). This does not apply if our legitimate interest is overridden by your interests or fundamental rights and freedoms; and
  • To protect your vital interests or those of others.

For candidates based in China, we can process your personal information only under any of the following circumstances:

  • Where your consent is obtained;
  • Where it is necessary for the conclusion or performance of a contract to which the individual concerned is a party, or for the implementation of human resources management in accordance with the labour rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
  • Where it is necessary for the performance of statutory duties or statutory obligations, such as providing your personal information to the social insurance authorities for the purpose of making social insurance contributions;
  • Where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
  • Where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
  • Where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the law; and
  • Other circumstances prescribed by laws and administrative regulations.

How long do we keep your personal information?

We will keep your personal information only for as long as we have to so we can complete the recruitment and pre-employment screening activities we have explained in this Privacy Notice. For candidates based outside of China, once recruitment and pre-employment screening activities are complete, we may need to keep it longer because of a legal action, or an investigation involving GSK. For candidates based in China, after the recruitment screening activity is completed, or after the job vacancy you apply for is cancelled, we will retain your personal information in accordance with relevant laws and regulations and GSK's global records retention schedule.

In some jurisdictions, laws and regulations tell us how long we must keep your personal information. How long depends on the laws of the jurisdiction you are in when you share the information with us.

If we offer you work, and you decide to accept, we will send our Employee Privacy Notice to you. The Employee Privacy Notice explains how we use, store and protect the personal information of our employees.

Additional information for candidates based in China, after the storage period of your personal information expires, we will delete or anonymize your personal information to make it not accessible and keep relevant deletion or anonymization record, except for the personal information that must continue to be stored for a longer period of time according to laws and regulations.

With whom do we share your personal information?

For candidates based outside of China, the following applies:

We share your personal information on a need-to-know basis, and to the extent necessary to follow laws and regulations, and to manage and run the activities related to the recruitment process.

In general cases, we share your personal information only with teams in our GSK companies and affiliates who need to see it to do their jobs.

In some cases, our recruitment and pre-employment screening activities are done for us by specialised service providers. We will share your personal information with their people and teams who need to see it as part of their job. 

We will also share your personal information with other specialised service providers who work with us, for example:

  • Event and travel agencies;
  • Technology suppliers who work with us to develop and improve our digital forums and apps; and
  • Professional advisors, such as auditors, accountants and lawyers.

We will also share your personal information with local or foreign regulators, or government and law enforcement authorities if we need to do so by law. These may be in or outside your country of residence.

Will your personal information be shared, transferred or disclosed?

For candidates based in China, the following applies:

We share your personal information on a need-to-know basis, and to the extent necessary for the purposes listed in “How do we process your personal information” and provided that laws and regulations are followed.

Shared within GSK Group

We share your personal information with members of the GSK group. You can query the name and contact information of GSK affiliates by accessing GSK’s worldwide contacts. We promise that all sharing is limited to your necessary personal information and is subject to this Privacy Policy; If we want to change the purpose of using and processing personal information, we will ask your authorization again. At the same time, we will strictly comply with the requirements of relevant laws and regulations on cross-border data transmission.

Shared with non-affiliated third parties

We will share your personal information with non-affiliated third parties under the following circumstances:

  • Based on laws, regulations or requirements of competent authorities: share your personal information externally in accordance with laws, regulations or mandatory requirements of regulatory agencies, governments and law enforcement authorities; and
  • Third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, corporate cooperation, joint promotion, transfer or other disposal (including in connection with any bankruptcy or similar proceedings) of all or any part of GSK's business, assets or shares.

Entrusted processing

We may also share your personal information with the following third-party service providers and professional consultants. These third-party service providers and professional consultants shall ensure the confidentiality and security of your personal information, and handle personal information only within the scope of processing purpose, processing method and type of personal information agreed with GSK and comply with applicable laws:

  • Specialised service providers who cooperate with us in recruitment and pre-employment screening activities
  • Event and travel agencies;
  • Equipment, systems and IT service providers; and
  • Professional advisors, such as auditors, accountants and lawyers.

Transfer

We will not transfer your personal information to any company, organization or individual, except:

  • Transferring with your explicit consent: After obtaining your explicit consent, we may transfer your personal information to other parties;
  • During merger, division, dissolution or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new entity holding your personal information to seek for consent from you. We will comply with the corresponding notification and other obligations in accordance with the law.

Public disclosure

We reserve the right to disclose your personal information in accordance with the requirements of law, and we will disclose your information when we disclose it in accordance with the requirements of regulatory authorities, perform judicial procedures, service procedures, court orders or to protect the safety, interests and property of customers, the public or GSK. In addition, we will disclose your designated personal information according to your requirements in the disclosure method that you separately give consent to.

In what instances do we transfer your personal information outside of your home country?

Note: For candidates based outside of China, the following applies: (For candidates based in China, please refer to” In what instances do we transfer your personal information outside China?”

We work all over the world. Therefore, we may need to transfer and use your personal information outside of the country where we collect it from you. We implement appropriate measures to protect your personal information when we transfer your personal information outside of your home country such as data transfer agreements that incorporate standard data protection clauses. The data privacy laws in the countries we transfer it to may not be the same as the laws in your home country. Law enforcement agencies, regulatory agencies, security authorities or courts in the countries we transfer your personal information to may have the right to see your personal information. 

Additional information if you are based in the European Economic Area (EEA)

The European Commission recognises that some countries outside the EEA have similar data protection standards. The full list of these countries is available here.

If we transfer your personal information to a country not on this list, we do so based on our Binding Corporate Rules (BCRs) and standard contract clauses adopted by the European Commission. These enable us to make international transfers of personal information within our group of companies and meet the data protection laws of the European Union and the General Data Protection Regulation (GDPR).

In what instances do we transfer your personal information outside China?

Note: For candidates based in China, the following applies:

In principle, the personal information collected and generated in the People’s Republic of China will be stored in the People’s Republic of China. Since GSK is a multinational corporation which operates globally, based on the needs of improving coordination of functional management within the GSK Group and optimizing the effectiveness of human resources management, your personal information as listed below might be stored in or transferred to other countries or regions or accessed by overseas jurisdictions, to achieve the purposes described in this Privacy Notice: name, telephone number, email address, work experience, academic qualification, gender, date of birth, address, information related to CV, bank account number, national ID, reimbursement records.

The overseas recipients include GlaxoSmithKline Services Unlimited (at 980 Great West Road, Brentford, Middlesex, TW89GS, United Kingdom), GlaxoSmithKline LLC (at Corporation Service Company, 251 Little Falls Drive, Wilmington, Delaware, 19808, United States) and other GSK’s overseas affiliates. You can check the names and contact information of GSK's overseas affiliates by visiting GSK's global contact information.

In addition, in order to complete recruitment and pre-employment screening activities more efficiently, the overseas recipients may engage third-party service providers (for specific names and contact information, please inquire through the contact information in this Privacy Notice) to assist us in providing relevant service support. During this process, such third-party service providers will act on behalf of GSK to process your personal information.

The personal information protection laws of the countries or regions where the recipients are located to which we transfer data may differ from the laws of China. We implement appropriate measures to protect your personal information when we transfer your personal information outside of China such as data transfer agreements with the data recipients that incorporate standard data protection clauses or cross-border data transfer security assessment, and we will also fulfill the obligations of cross-border transfer of personal information accordingly. 

How do we protect your personal information?

We want to make sure your personal information is not shared with or used by those not allowed to see it. We use a variety of security measures and technologies to help protect your personal information.

We carefully choose service providers to work with, and check they have security measures and technologies in place to protect your personal information. We do not allow our service providers and suppliers to use your personal information for their own purposes.

Additional information for candidates based in China, we have used industry-standard security safeguards to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable steps to protect your personal information.

We also require all personnel who may have access to your personal information to fulfil corresponding confidentiality obligations. Failure to fulfil these obligations may result in legal liability or suspension of the partnership with us. We carefully choose service providers to work with, and check they have security measures and technologies in place to protect your personal information. We do not allow our service providers and suppliers to use your personal information for their own and unauthorized purposes.

In the event of an unfortunate personal information security incident, we will promptly inform you of the following items in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, recommendations on the measures you can take to prevent and reduce risks on their own, remedies for you, etc. We will promptly notify you of the incident by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information incident individually, we will reasonably and effectively publish an announcement.

At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

What are your rights regarding your personal information?

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal information and the local law in your jurisdiction. Depending on this you may have the right to:

  • Ask us for copies of your personal information;
  • Ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
  • Ask GSK about the processing of your personal information;
  • Ask us to delete your personal information;
  • Ask us to restrict the processing of your information;
  • Object to our processing of your personal information;
  • Ask that we transfer information you have given us from one organisation to another, or to give it to you; and
  • Complain to your local data protection authority.

For candidates based in China, you further have the rights to:

  • Ask us to explain our rules for processing your personal information;
  • If we deny your request to exercise your rights or your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information, you can file a lawsuit in the People's Court in accordance with the law.

You can find out how to get in touch with us to ask us to do any of the above by looking at the ‘Contact Information and Privacy point of contact’ section.

For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do. For candidates based in China, after verifying your identity, we will respond to your request based on the above rights in a timely manner and give a reply and reasonable explanation within 15 working days after receiving your request.

If you object to us using your personal information or withdraw permission for us to use your personal information, after initially giving it to us, we will respect your choice in line with applicable law. However, by objecting or withdrawing your permission, we may not be able to complete the recruitment and pre-employment screening activities described in the  ‘How do we use your personal information’. For candidates based in China, please note that if your personal information is processed based on a statutory basis other than your individual consent, the processing will not be impacted by the withdrawal of your consent. In addition, according to the relevant laws, if you withdraw your consent, it will not affect the validity of any personal information processing activity conducted based on your consent before such withdrawal.

Our responsibility regarding websites that we do not own or control

Our careers portal may contain links to websites or mobile applications we do not own or control. Our Privacy Notice does not cover them. Please read the Privacy Notices on those websites and mobile applications if you would like to find out how they collect, use and share your personal information.

How do we process personal information of minors?

For candidates based outside of China, the following applies:

We use the personal information of minors only if the job is meant for an apprentice.

If you live in one of the countries of the European Economic Area (EEA) and you apply for an apprentice job, you are telling us that you are least 16 years old and that you can give us your personal information and take part in the recruitment process without your parents’ consent.

If you live in one of the countries outside of the EEA and you apply for an apprentice job when you are under age according to the laws of your country, we must have the permission of your parents or legal guardians to collect and use your personal information, as described in this Privacy Notice. 

For candidates based in China, the following applies:

We will not process the personal information of candidates under the age of 18. If you apply for our position, please make sure you are over 18 years old.

How do we update this Privacy Notice?

From time to time, we will update this Privacy Notice, so as to timely reflect the changes of national laws and regulations and the adjustment of our service policies. Any changes become effective when we post the revised Privacy Notice on our Privacy Centre. This Privacy Notice was last updated as of the “Last Updated” date shown above. If changes are significant, we will provide a more prominent notice to let you know what the changes are. For candidates based in China, the following applies: If such updates involve the rights of personal information subjects and matters that may cause you to change your consent or need to obtain your consent again (for example, the purpose of processing, the type of information collected, etc.), we will re-seek your consent to the updated Privacy Notice in accordance with the provisions of laws and regulations.

Who is the controller of your personal information?

GlaxoSmithKline(China) Investment Co., Ltd. and its affiliated companies are the controllers of your personal information.

Contact Information and Privacy point of contact

If you want to exercise your rights, have any questions about this Privacy Notice, need more information or would like to raise a concern, please contact us at Privacy contact information. Please do not use this email for general questions about recruitment or to send speculative applications.

If you would like to find out who your privacy point of contact in your country is, please click here: Privacy contact information or contact us using the information available here: GSK’s worldwide contacts.

For candidates based in China, if you want to exercise your rights, have any questions about this Privacy Notice, need more information or would like to raise a concern, please contact GSK China Privacy Office at cn.pharma-privacy@gsk.com. Please do not use this email for general questions about recruitment or to send speculative applications.