ZMBeidiao is engaged to provide pre-employment and employment background verification services (the “Services”) to its clients (“Clients”). For the purposes of compliance with the Personal Information Protection Law of the People’s Republic of China (“PIPL”), the Client is the Personal Information Handler and ZMBeidiao is the entrusted party as set out in Article 21 of PIPL.

ZMBeidiao respects your privacy and is committed to protecting your personal data and this privacy policy explains how your personal data is used by ZMBeidiao during the course of the Services and will comply with the provisions of this privacy policy and PIPL.

This policy describes how ZMBeidiao processes your personal data. In addition to this policy, you will have access to supplementary documentation, videos and/or notices provided to you at the time your personal data is collected and/or processed.

ZMBeidiao is the entrusted data handler appointed by its Client to perform the Services and has concluded an agreement with the Client to include terms that cover:

ZMBeidiao handles all personal information in accordance with the terms of the agreement with its’ Client and only acts under their instruction. ZMBeidiao does not collect, process or store personal information for any other purpose than that of providing the Services to its’ Client.

In some circumstances, ZMBeidiao needs to send your personal data to a third party. This may be an employer, where you were educated or a third-party vendor who assists in performing the Services. The Client has consented to such transfers of personal information to such third parties under the terms of the Agreement.

ZMBeidiao always acts under the instruction of its Client who will determine what personal data is collected and processed in order to provide the Services. For more information about what information is being collected and why, please speak with your prospective employer/employer.

You will be invited to participate in the Services via a candidate invite generated by our Client. The Services are provided via a secure platform (the “Services Platform”) which will be accessed through a secure link provided in the candidate invite. Once you have accessed the Services Platform, you will be asked to read an Information Notice which will contain all the details you need to know about the Services. Only when you have read and understood the Information Notice will you be asked to enter any personal data into the Services Platform. At the same time, you have the right to decide whether to accept the invitation through face recognition or fingerprint recognition, and authorize us to process your personal data by signing an electronic contract.

You will be asked to provide your consent for ZMBeidiao to collect and process your personal data on behalf of our Client. You will be provided with enough information to ensure that your consent is fully informed. You will not be asked to provide your consent until you have read and understood the Information Notice and you are encouraged to contact your prospective employer/employer if you have any questions in respect to the nature of the Services and the extent of the processing of your personal data so that you can exercise choice and control. Each type of verification that is to be carried out is listed in the Information Notice and the final Consent Form provided to you via the Services Platform. In addition, where a Source (please see definition below) requires a separate Consent form will be provided to you for signature prior to any personal data being processed or sent to such Source.

You may withdraw your consent at any time and ZMBeidiao has processes in place to deal with this.

Under the PIPL, “personal information” means any information, whether recorded in electronic or another format, that relates to an identified or identifiable natural person, excluding anonymized information. “Sensitive personal information” means personal information that, if leaked or if used illegally, is likely to cause harm to a natural person’s personal dignity or endanger his or her personal safety or the safety of his or her property.

In order to provide the Services, and to ensure that any information reported back to a Client is accurate, your personal data must be collected. You will be asked to provide only the personal data that is required to perform the Services. The types of personal data that may be required:

The Information Notice that you will access when you log in to the Services Platform provides further detail of the personal data collected and what Services that personal data will be used for.

The Services Platform collects session cookies only which are stored on your computer only during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.

The personal data processed during the Services will be determined by ZMBeidiao’s Client. It is likely that ZMBeidiao’s Client will request your employment and education background be verified but may also request other bespoke services such as verification of any credit, criminal or open-source information.

All relevant information will be set out in the Information Notice that you will access from the Services Platform so that you are fully informed of the nature of the Services.

Your personal data will be directly stored on the Services Platform which resides on servers in the China. The Services Platform is ISO27001, ISO9001 and DJCP Level III certified, and measures are in place to protect personal data from accidental loss and from unauthorized access, use, alteration or disclosure and information security measures are in place, including access controls, physical security and robust information collection, storage and processing practices. ZMBeidiao also ensure that where electronic transfer of Personal Data to/from its representatives takes place that such transfers are also appropriately protected and are in compliance with relevant data protection legislation and in accordance with any instructions provided by a data source. As contracted with ZMBeidiao’s Clients provisions are in place within ZMBeidiao in order to ensure an adequate level of data protection for all transfers of personal data.

Your personal data may be transferred in these circumstances:

[To ZMBeidiao’s Client:]

As part of the Services ZMBeidiao produces a Screening Report detailing the results of any verifications performed against the personal data you provide to us via the Services Platform. This Screening Report is accessed by the relevant ZMBeidiao’s Client.

Each ZMBeidiao’s Client has its own secure account and designates users of that account, including access rights to reports, to ensure maximum security of Screening Reports. Many clients chose to view the Screening Report directly from their secure account but some may choose to download a copy of the Screening Report and retain on their own systems. You should contact your prospective employer/employer for further information.

[To a third party:]

The third parties are organizations, institutions, agencies or individuals from which information is collected for the purposes of fulfilling the Services only and may include local vendors, employers, educational establishments, referees, government agencies, courts, data providers or repositories (“Source” or “Sources”) or ZMBeidiao’s representatives (“Representatives”) who are performing specific research in connection with the Services (together “Third Parties”).

In respect to a transfer of your personal data to a Source or Sources outside of the People’s Republic of China, this will be dependent on your footprint during the screening period set by ZMBeidiao’s Client. Where your footprint is outside the People’s Republic of China, your personal data will need to be transferred to the relevant Source(s).

We will only transfer your personal information for specific and definite purposes pursuant to the principles of lawfulness, fairness, necessity and good faith, and only transfer the personal information to the extent necessary for the specific purposes you are informed of.

No: we do not make any decisions at all in respect to you or your personal data whether that is automated or otherwise.

No: your personal data is used only to provide the Services. Once the Services are completed your personal data will be deleted from the Service Platform in accordance with data retention periods.

ZMBeidiao’s standard data retention policy on the Services Platform is 6 months from the date that the Screening Report is completed. However, a Client may set their own customized retention period which they will make available to you on your request. The data retention period is clearly set out in the Information Notice.

You have certain rights arising under privacy legislation in respect to the personal data that will be processed in relation to the pre-employment screening, such as rights of access, rectification and erasure. Under such relevant privacy legislation your rights are exercisable against the Personal Information Handler (who is ZMBeidiao’s Client and your prospective employer/employer) and you should direct your requests to them at the address they provide to you.

As your Personal Data is being processed with your consent, you have the right to rescind that consent at any time. To do this you may either

contact the Personal Information Handler, who will notify ZMBeidiao of your request;

contact service@zmbeidiao.com and we will cease to process your personal data, whether that be all your personal data or a specific component to which the withdrawal of consent relates.

If you contact ZMBeidiao directly, we will then contact the relevant Client to notify them that consent has been withdrawn. Processing will only recommence if you reinstate your consent.

We encourage you to speak to the Personal Information Handler (your prospective employer/employer) to discuss any concerns or reasons that led to the withdrawal of your consent.

Please note that should any processing of your Personal Data take place before you withdraw your consent, such processing will be unaffected by such withdrawal.

We commit to handle your personal data in a way that provides you comfort and confidence. However, if at any time you have concerns over the handling of your personal data you are encouraged to contact the Personal Information handler (your prospective employer/employer) and ZMBeidiao will cooperate with any investigation to resolve any issues.

If you wish to contact ZMBeidiao directly then please do so at service@zmbeidiao.com. We are committed to protecting your personal data and investigating and resolving any complaints about our collection or use of your personal data.

We may change this policy from time to time so it accurately reflects our practices and legal requirements. You should check back regularly to stay informed of our privacy practices. Your continued use of our Site and Services following the posting of changes to this Policy will mean you agree with, and consent to be bound by, the new revised Privacy Policy.