This policy applies only to applications for our Hong Kong location:

Personal Information Collection Statement

Last updated: June 2022

Personal Data – Your privacy is important to Lindamood-Bell Learning Processes, a registered non-Hong Kong company incorporated in the United States of America with limited liability (the “Company”). In the context of the Company’s recruitment process and/or your employment (if hired) it is necessary for the Company to collect, use, store, and transfer (together, “processing”) certain personal information (“Personal Data”) about you. This Personal Data includes (but is not limited to): (1) identification and contact information (both business and personal), including name; date and place of birth; age;  addresses (both postal and residential), email addresses and phone numbers; login identification and passwords for Company systems; Company internal identification number; Hong Kong ID or other government identification numbers;  citizenship/nationality, passport, visa, work authorisation, and residency permit status; gender, marital or domestic partner status, and family information; photograph; and next of kin and/or emergency contact details; (2) information relating to your job and work history, including your business unit and management reporting structure; job title, level, function, and nature of your duties and responsibilities; employment status; work-related evaluations and assessments such as professional performance appraisals or reviews (including subjective or unstructured narrative comments); time and attendance records; years of service and work history; education, skills, and abilities; professional biography; training and development; and work-related grievances, internal investigations, including reports that may be submitted anonymously through a whistle-blowing procedure, and corrective action plans; information regarding termination of employment and terms and conditions of employment; (3) payroll, administrative, and benefits-related information, including compensation data (including salary deductions, child or spousal support payments or court-ordered garnishments/payments); certain financial information such as bank account numbers for direct salary deposit, company credit cards, expense accounts and reimbursement information; entitlement and participation in Company-related benefits such as health plans and Mandatory Provident Fund; insurance or pension beneficiary information; bonus or equity program participation (including any bank or brokerage account data, awards and enrollment information); medical information as it relates to job role, leaves, and benefits entitlements; recruitment, engagement or training records; and (4) miscellaneous personal data, including travel history, relationship to dispute or litigation in which the Company has an interest; criminal record, credit and background checks; intellectual property, patents and inventions; professional associations, memberships and affiliations; military service if required for benefits and/or leave administration; and information that may be collected or contained on Company-approved devices; as well as audio/visual recordings of, among others, your participation in or presence at actual or practice student sessions and office procedures; and (5) the above information as may be provided by you about members of your family and other dependents.  The Personal Data described in this section may also consist of “Sensitive Personal Data,” which includes information relating to: your ethnic or racial origins; religious beliefs or other beliefs of a similar nature; trade union membership; physical or mental health; and the commission or alleged commission of any criminal offence or the sentence in relation to any such offence (excluding spent convictions). Personal Data and Sensitive Personal Data are together referred to herein as “Data.”

Purposes – The purposes for which the Company processes Data include: (1) meeting the Company’s legal and regulatory obligations, such as the payment of payroll, income, foreign, or other taxes; complying with immigration, work permit, and health and safety obligations; and providing a work environment free from unlawful discrimination and complying with other employment legislation; (2) maintaining and improving effective Company services and procedures and human resources management and complying with the Company’s contractual obligations under an employment agreement, service contract, or otherwise, including administering salary, bonuses, health and other benefits, leave entitlements, and expense tracking and budgeting; (3) allocating work, tracking assignments, determining qualifications for specific projects, and providing for and monitoring training requirements and professional development (including promotion and career development activities), as well as facilitating employee performance evaluations, disciplinary and grievance hearings; (4) monitoring and complying with contractual obligations, Company policies and codes of practice, and management reporting requirements and facilitating internal investigations and preventing and detecting crime; (5) maintaining one or more internal and external employee directories with information such as name, title, location, work contact information, and reporting lines to facilitate communications within the Company and for communicating with your family members in relation to death, illness, injury or emergency in connection with work; (6) due diligence in the event of a potential sale of part or all of the Company, its business, or any part of an affiliated entity or other corporate restructuring or transaction; (7) responding to data requests and other preparation in the context of potential or actual litigation or other investigation; (8) assessing your suitability for a vacancy within the Company or other company within the Group (as defined below), and negotiating with and making an offer of employment to you; (9) promoting and marketing the business of the Company via various media, including but not limited to newspapers, magazines, the Company’s website and social media platforms; (10) any residual employment-related activities after cessation of your employment in relation to your former employment by us, including but is not limited to, the provision of job references and processing applications for re-employment; (11) ensuring occupational health and safety and making relevant decisions, such as determining your fitness for work and safeguarding the health and well-being of other employees and visitors; and (12) any other purposes directly or indirectly related to the above. If you do not provide complete and accurate Data to the Company as and when it is required, there may be potentially serious consequences for you and, depending on the circumstances, your prospective employment or (if hired) employment relationship with the Company.

Access and Review – From time to time, the Company may ask you to review and update your Data.  You may access and update your Data more frequently if you wish to the extent permitted by applicable law and, in some instances, you may have rights under applicable laws and regulations to access such Data.  

Transfer – As the Company is part of a larger group of companies (“Group”) operating internationally, the Company may transfer Data to its own operations or to other Associated Companies (as defined in section 2 of the Companies Ordinance (Cap. 622) and it refers to the Associated Companies of the Company) located outside of your country (including in countries where data protection laws and regulations may differ from those in your jurisdiction) for further processing for the purposes described above and to streamline, harmonise, and increase the quality, timeliness, accuracy, and security of Data throughout the Group. In particular, data may be transferred to databases for human resources information housed by an Associated Company in the United States and may be accessed elsewhere.  Likewise, the Company may also transfer Data to third parties outside the Company, including: (1) governmental and regulatory bodies such as tax and labor authorities and law enforcement when required by applicable laws for purposes including e.g. to prevent and detect crime or in connection with a corporate restructuring or transaction; (2) legal and tax advisors, auditors, and other outside professional advisers; (3) potential purchasers of or investors, or any other parties involved in a merger, acquisition or due diligence exercise in respect of, part or all of the Company, its business, or any or part of any affiliated entity; (4) vendors that provide products or services to the Company or a related entity, such as technology suppliers, insurers, banks, medical practitioners, relocation services, administrators of the Company’s mandatory provident fund scheme or payroll, parties involved with promotional or marketing purposes in relation to the Company’s business, cloud or database services providers and other parties involved in the operation of the Company’s business or management of the Company’s human resources, private health companies and any other service providers which the Company engages to perform the functions and purposes listed above on the Company’s behalf; and (5) anyone you authorise.  These recipients may be located outside of your country, where data protection laws and regulations may differ from those in your jurisdiction and may not be substantially similar to, or serve the same purpose as the data protection law in Hong Kong.  Personal Data in the internal employee directory may also be accessed, within and outside your country, by employees of the Company or an Associated Company, as well as by authorised third parties. 

Monitoring – The Company or an Associated Company may monitor and record your use of its communication systems and equipment (including its telephone, mobile phone, voicemail, e-mail or computer systems) without further notice to ensure that its rules are being complied with and for legitimate business purposes.  Any use by you of such communication systems and equipment shall be in accordance with any policies that the Company or Associated Company may issue from time to time. Private use should be conducted outside of working hours, away from the Company's premises and without using Company communication systems or equipment.   Your communications on the Company’s communication systems and equipment may be used as evidence in disciplinary or legal proceedings against you. 

Retention of Data – It is the Company's policy to retain certain Data of unsuccessful job candidates or employees when they cease to be employed. This Data may be required for various purposes including for any residual employment-related activities, including for example, provision of references, processing of applications for re-employment, matters relating to retirement benefits and allowing the Company to fulfil any of the Company's contractual or statutory obligations.

Dependents – If you provide the Company with Data about members of your family and/or other dependents, such as information related to health and other benefits that they may obtain through your employment, it is your responsibility to obtain the consent of these individuals (provided they are legally competent to give their consent) for the processing (including transfer) of that Data by the Company as set out in this notice.  By providing your family and/or other dependents’ personal information you confirm that you have obtained their consent and, with respect to any individuals not legally competent to give consent, you consent on their behalf (and you confirm that you have the authority to do so).

Company Contact Information – You may request access to, and correction of, your Data in relation to your job application or (if hired) employment with the Company. To request access to, copies of, or amend your Data, or ask any questions related to this Notice or the Company’s privacy policies and practices, you should notify the Company by contacting any member of the Legal or HR teams.