China Addendum to the Slaughter and May Privacy Notice

During the course of working with you or the organisation you work for, we may collect, process and transfer personal information in relation to your matters. If the Slaughter and May Beijing Office (“SandM BJO”) collect or you or your employer, as well as relevant third parties, provide personal information to SandM BJO, this Addendum will apply. This Addendum supplements and constitutes an integral part of the Privacy notice.

Cross-border transfer of your personal information

For the purposes of business development, business acceptance process and provision of legal services, including communicating with relevant parties and individuals, providing legal services and complying with contractual, legal and regulatory requirements, SandM BJO may transfer client-related personal information to Slaughter and May (Hong Kong) (“SandM Hong Kong” or “Overseas Recipient”), the Hong Kong office of Slaughter and May. In certain cases, third-party service providers may be engaged by SandM Hong Kong to operate and maintain relevant overseas systems and provide other supporting services.

Slaughter and May is an international law firm. To the extent necessary for conducting business development and business acceptance process, SandM Hong Kong may provide or allow access to the personal information by the firm’s other overseas offices as part of our regular business.

The personal information may be stored in such overseas systems utilised by the firm and used by authorised individuals for the purpose of business development, business acceptance process related to client management, legal services and those purposes as stated in the Privacy Notice.

Outlined below are types of personal information transferred outside mainland China:

  • Personal identifier, including name, proof of address, gender, date of birth, government issued ID numbers, photographs without specific technical processing;
  • Contact data, including email addresses and telephone numbers (home and work);
  • Position data, including title, role, grade, job description; details of directorships;
  • Contractual data, including copies of employment contracts or details of directorships;
  • Employment data, including employee number, employment history including copies of CVs;
  • Financial data, including bank details, salaries, tax filing records, investment information, pensions, benefits, loans granted, received, surrendered, or repaid;
  • Ethnicity to the extent that such information is shown on government ID cards, which SandM BJO collect from time to time for client due diligence purposes (even though SandM China do not specifically collect or process information in relation to ethnicity);
  • Personal characteristics and social circumstances.

Sensitive personal information

We may process certain sensitive personal information if it is needed for achieving purposes set out in the Privacy Notice. Specifically, we process and transfer your government issued ID numbers, photographs without specific technical processing and financial data, which are necessary for verification of your identity and complying with business acceptance processes. We only process sensitive personal information about you in accordance with the principle of necessity. If you or your employer refuse to provide such personal information, we may not be able to verify your identity or provide legal services.

Please note that as a legal adviser, SandM BJO may collect materials containing your personal information that are provided by you or collected on your behalf. The personal information processed by SandM BJO for providing legal services varies depending on the specific legal matters at hand.

Your personal information is considered private and confidential. For cross-border data transfer, we will perform relevant procedures and formalities in accordance with data protection legislation and will ensure that adequate safeguards have been provided by the entity receiving the information.                  

Your rights in connection with personal information

In addition to the personal information rights that may apply to you and are set out in the Privacy Notice, you are entitled to exercise the following rights:

  • request an explanation of the Privacy Notice (including this Addendum) from SandM BJO.
  • request to transfer personal information to another data controller (personal information processor under Chinese data protection laws) to the extent permitted by applicable law.
  • request a copy of your personal information processed by SandM BJO.

We will respond to your requests related to your personal information within 15 working days of receiving such request.

Contact information

You may contact the Overseas Recipient by writing to the Senior Partner of  Slaughter and May Hong Kong, at 47th Floor, Jardine House, One Connaught Place, Central, Hong Kong, or by using the [email protected] email address.

If you would like to exercise your personal information rights or request an explanation of personal information processing rules, please contact the Partner of Beijing Office at 2906-2909 China World Office 2, No.1 Jianguomenwai Avenue, Beijing 100004, People's Republic of China.

Last updated: April 2024