PERSONAL INFORMATION PRIVACY NOTICE (the “Notice”) FOR CANDIDATES
Yanfeng Global Automotive Interior Systems Co., Ltd. (registered in China, Address: Room A-786, No. 188, Yesheng Road, China (Shanghai) Pilot Free Trade Zone), and its subsidiaries and affiliated companies (collectively, YFAI, we, us or our) care about your privacy and are committed to processing your personal information in accordance with fair information practices and applicable data privacy laws.
TheNoticeexplains how YFAI handles the personal information of applicants f in the course of its human resources activities,specifically in connection with your application for a job with the hiring YFAIaffiliate and for purposes laid down in theNotice. We may amend theNotice from time to time, should it become necessary to do so. The Noticemay also be supplemented by other statements as needed to comply with local requirements in the country where you live.
For more information regarding how third-party recruitment portals you may have used collect, process or store your personal information, reach out to that third party or read their respective Privacy Notice.
Collection and Use of Personal Information
We may collect your personal information to administer our applicationand for the purposes specified below. We may collect personal information, either directly from you or from third parties including your references, prior employers, educational institutions you attended,public databases, social media platforms or recruitment companies. We may collect, use and transfer your personal information through automated and/or paper-based data processing systems. We have established routine processing functions. We also process personal information on an occasional or ad hocbasis.
We may collect the following types of personal information:
- Personal identification and contact information, such as your name, address, and phone number;
- Immigration, right-to-work and residence status;
- Educational and training information, such as your educational awards, certificates and licenses;
- Recruitment data, such as CV, résumé, cover letter, previous work experience, career history, skills and competencies and other work-related qualifications;
- Information relating to references;
- Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships);
- Job interview notes and assessment results,and
- When using YFAI’s Career Site: Username and password, language preference, activities within our recruitment portal; Website related information like cookies.
Providing personal information to us, specifically through YFAI’s Career Site, by email or offline is voluntary, but necessary for the recruiting process. If you do not provide sufficient information, the local YFAIcompany considering you for the hiring process may be unable to consider your employment application or, if you are hired, your subsequent promotion, transfer or relocation.
Sensitive Personal Information
In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable law. Sensitive personal information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place and after having first obtained your informed consent, if required by law.
Except as specifically requested or legally required, we ask that you avoid submitting information which may qualify as sensitive information under applicable law. But, in certain cases we may ask questions about race/ethnic origin, gender, and disability of our applicants, for the monitoring of equal opportunity compliance. We may also ask you to provide criminal records or credit history, where permitted by applicable law and necessary for specific job role you are applying for.
Sensitive information includes data revealing racial or ethnic origin, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic data, biometric data for the purpose of uniquely identifying a natural person, political opinions, religious or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings.
We process personal information for the following purposes:
- workforce planning, recruitment and staffing;
- To process your application. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
- To assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
- To conduct reference checks. We will engage in these activities to comply with a legal obligation, as applicable, or based on our legitimate interests;
- To respond to your inquiries and communicate with you about your application, and to send you information regarding YFAI’s Career Site and changes to our terms and policies. We will engage in these activities to manage our prospective contractual relationship with you;
- To conduct background checks if we offer you a position. We will engage in these activities to comply with a legal obligation, where applicable, or based on our legitimate interests;
- legal defense and compliance, including compliance with government authority requests for information;
- the administration of information systems;
- to protect YFAI, its workforce, and the public against legal liability, fraud, abuse, or threat to the security of our networks, communications, systems, facilities and infrastructure; and
- other legal and customary business-related purposes.
If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.
Legal Bases for Processing
These uses of personal information are based on one of the following legal bases, as applicable:
- the need to process your personal information to take steps to enter into an employmentcontract with you;
- YFAI’s legal obligations, specificallyas the potential future employer;
- YFAI’s legitimate business interests including general human resource administration, contractual obligations with third parties, management of network and information systems security, and the protection of YFAI’s assets; and
- in some specific and limited circumstances, your consent.
Disclosures and Categories of Recipients
We may disclose your personal information for legitimate purposes to:
- Other YFAI entities, more specifically;
- YFAImay share personal information of candidates with its affiliates that are involved in evaluating candidates for a given position. YFAIwill remain responsible for personal information that is jointly used with affiliates.
We will limit access to such personal information to personnel that will need to know the information for the purposes described in the Notice, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.
- YFAI also shares personal information with approved third-party service providers to facilitate services they provide to us, including hosting and operating YFAI’s Career Site, recruiting assistance, and background check processing.
- Any recipient, if we are legally required to do so, such as by court order or applicable law;
- Any recipient, with your consent, such as for employment verification;
- A newly formed or acquiring organization if YFAI is involved in a merger, sale or a transfer of some or all of its business;or
- Any recipient when reasonably necessary such as in the event of a life-threatening emergency.
Any personal information you submit to YFAI’s Career Site will be collected in the country or countries, where the site is located and will be subject to local applicable laws. However, if we share your personal information you provided (specifically via YFAI’s Career Site, via email of offline) with an YFAIaffiliate located in another country, the affiliate will handle your personal information in accordance with the Notice. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
Considering the fact that YFAI is an international company and members of talent and acquisition team are based also outside the EEA, your personal information may be transferred outside of the country where you workand live, including to countries that do not provide the same level of protection for your personal information. YFAI is committed to protecting the privacy and confidentiality of personal information when it is transferred.
If you are a resident of the EEA, we may transfer your personal information to countries outside the EEA. Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.For transfers to other countries,we will ensure that adequate protection exists either through appropriate contractual arrangements or as required by applicable law. YFAI has for example entered intoStandard Contractual Clauses with manycontract parties and will do it in the future if required.
We take reasonable steps to ensure that personal information is accurate, complete, and current. Please note that you have shared responsibility with regard to the accuracy of your personal information. Any information you submit must be true, complete, and not misleading. Purposely submitting inaccurate, incomplete, or misleading information may lead to rejection of your application during the application process or, if identified after employed with YFAI, disciplinary action including immediate termination of employment. Please notify Human Resources of any changes to your personal information.
In addition, it is your responsibility to ensure that information you submitteddoes not violate any third party’s rights.
If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
Your Personal Information Rights
Access, Correction and Transmission.You may reasonably access the personal information pertaining to you that is on file with YFAI. You also have the right to request that we correct incomplete, inaccurate or outdated personal information. To the extent required by applicable law, you may also request that we transmit personal information you have provided to us to you or to another company.
If you register on YFAI’s Career Site, you may access, review, and change your personal information stored therein by logging into the respective portal and updating your account information, as appropriate. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. We encourage you to promptly update your personal information if it changes or is inaccurate.
Objection.We respect your right to object to any uses or disclosures of your personal information that are not (i) required by law, (ii) necessary for the fulfillment of a contractual obligation (your employment contract), or (iii) required to meet a legitimate need of YFAI as a potential employer (such as general human resource administration, management of network and information systems security, or protection of YFAI’s assets). If you do object, we will work with you to find a reasonable accommodation. You may also withdraw your consent at any time in relation to our processing of personal information based on your consent.
Deletion.You may request the deletion of your personal information as provided by applicable law. This applies, for instance, where your information is outdated; where the processing is not necessary or is unlawful; where you withdraw your consent to our processing based on such consent; or where we determine we should accommodate an objection you have raised to our processing. In some situations, we may need to retain your personal information pursuant to our legal obligations or for the establishment, exercise or defense of legal claims.
Restriction of processing.Similarly, and where provided by applicable law, you may request that we restrict processing of your personal information while we are answering your request or complaint pertaining to (i) the accuracy of your personal information, (ii) our legitimate interests to process such information, or (iii) the lawfulness of our processing activities. You may also request that we restrict processing of your personal information if you wish to use the personal information for litigation purposes.
You may exercise these rights free of charge by contacting our Privacy Office as described below. However, YFAI may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive in particular because of its repetitive character. In some situations, YFAI may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of YFAI or others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable law. In all cases, you have a right to file a complaint with a Data Protection Authority.
YFAI takes precautions to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal information is stored, and we contractually require our suppliers and service providers to protect your personal information.
Your personal information will be retained as long as necessary to achieve the purpose for which it was collected, usually for the duration of the application and - in case of a subsequent employment contract -for the duration of such employmentand for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
How to contact us and obtain further information
If you have any questions about the Noticeor if you believe that your personal information is not handled in accordance with the applicable law or the Notice, or if you want to exercise your rights, you have several options:
Because email communications are not always secure, please do not include sensitive information in your emails to us.
- Contact the Human Resources department
- You may also contact YFAI 24-hour Integrity Helpline:
- File a report online via the Internet: www.yfai.ethicspoint.com
- File a report by phone: you will find toll free phone numbers listed for all countries where YFAI conducts business on www.yfai.ethicspoint.com. The website is available in your local language.