Current or former Shell employee, contractor or dependent

All activities on Shell IT equipment and/or when connected to the Shell IT network may be monitored for legitimate business purposes.  For further information see the personal use guidelines http://sww.shell.com/it/irm/legalandregulatory/personal_use.html.

All Shell Staff receive an access badge which allows Shell to record the date, time and access points made by individuals within Shell premises and assets.  The data from the access and security systems are used:

• for health, safety and security purposes, specifically the protection of Shell assets, Shell Staff and visitors to Shell premises;
• to comply with legal and regulatory requirements, specifically where there is a local legal requirement to provide information to government/regulatory authorities;
• to monitor (on an aggregated basis) the number of individuals entering and working in a Shell premise for human resources and real estate planning; and
• in the case of contractors only (not Shell employees) the date and time of their entry and exit of Shell premises is used for the purposes of financial management and control.

Most of our premises and assets are equipped with surveillance cameras (CCTV). Where surveillance cameras are used they will be identified.  Surveillance cameras are used for health, safety and security specifically the protection of Shell assets, Shell staff and visitors to Shell premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or actual criminal activity, in which case they may be viewed by internal Shell investigation teams and externally if legally required or permitted by law enforcement or other government authority.

In order to comply with legal and regulatory obligations, to protect Shell’s assets and employees/contractors and specifically to ensure that Shell can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available or government issued sanctions lists and is compared with information held about you by Shell (for example from the Conflict of Interest register – see here for more information). Any personal data collected through the screening will not result in any automated decision making regarding suitability for continued employment, internship or engagement as a contractor.

Hankook Shell Oil Company Limited, along with your employing company (or in the case of dependents, the employing company of the Shell employee) either solely or jointly with its affiliates within the Shell group of companies.

In the case of individual contractors, the company within the Shell Group that has contracted your services solely or jointly with its affiliates within the Shell group of companies and your external contracting/employing company/agency.

Your personal data is exclusively processed for the purposes referred to above (or for a secondary purpose where it is closely related, for example such as storing it) and will only be shared on a strict need to know basis with:

• Other companies within the Shell group of companies, including to those which may be located outside of your location and the Economic European Area (“EEA”); Specifically, we provide the personal information as stated in each item below:
• Authorized third party agents, service providers and/or subcontractors of Shell Specifically, we delegate personal information processing services as set forth below. In the event that the delegatee or the contents of delegated services is changed, we will disclose the information thereon through this Privacy notice.;
• and, A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell company/companies is subject to or as permitted by applicable local law.

Where the personal data is transferred to companies within the Shell Group and/or to authorized third party agents service providers and/or subcontractors who may be located in or outside of your location (including outside of the European Economic Area) we take organizational, contractual and legal measures to ensure that the personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard the personal data.  These measures include Binding Corporate Rules for transfers among the Shell Group and European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. You can request a copy of these by contacting privacy-office-hsoc@shell.com

Given the nature of the Shell Group your personal data and that of your dependents may be transferred to countries outside of your location. Where that happens, we take steps to ensure that your privacy rights and those of your dependents continue to be protected in line with Shell’s Binding Corporate Rules and applicable law.

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

We shall take the following technical, administrative and physical actions required to ensure the safety of personal information:

• Minimize the number of employees handling personal information and provide training for them.
• Conduct a periodic self-audit.
• Establish and implement an internal management plan.
• Encrypt personal information.
• Take technical measures against hacking, etc.
• Control access to personal information.
• Retain log-in records and prohibit forgery and alteration of log-in records.
• Adopt locking system for document security.
• Control access from unauthorized persons.

All information, including personal data is managed in line with the Shell Group standards for Information and Records Management and securely deleted once no longer required for a legitimate business purpose or for a legal/regulatory purpose.

With some exceptions required to comply with local legal requirements:

• Information contained within personnel files is held for no longer than 10 years once your employment has terminated;
• information relating to retirement benefits are held for no longer than 99 years from the commencement of employment;
• any personal data gathered as part of the screening against publicly available or government issued sanctions lists and media sources is held for no longer than 15 years after it was first gathered.
  
• the names, date, time and access points for all individuals entering Shell premises are held for 3 years from each access;
• where an individual has been dismissed or had their contract terminated due to serious misconduct, including breaching the Shell Life Saving Rules or breaching the Shell Code of Conduct that information is held for up to 30 years post termination.

In all cases information may be held for a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or b) a shorter period where you or your dependents object to the processing of the personal data and there is no longer a legitimate purpose to retain it.

We will destroy the personal information within [five] days from the expiration date of the retention period. If the personal information becomes no longer needed as the purpose of processing such information has been achieved or our business has been closed, we will destroy such information within [five] days from the date on which the processing of such information is deemed unnecessary.

Any printout, document, etc. containing personal information will be destroyed by incinerating or shredding such into pieces, and personal information in the form of electronic file will be destroyed by permanently deleting it in an irrevocable manner.

 You can find more information here regarding Shell Group Records management including local variations:

http://sww.shell.com/ethicsandcompliance/im/Records/classifyingRecords.html

We aim to keep our information about you as accurate as possible.  You can access your personal data, request correction or deletion of the personal data (but only where it is no longer required for a legitimate business purpose) and request that the processing of your data is restricted. For those individuals who have access to HR Online you can access your personal data through:

https://hronline.shell.com/

Alternatively, please contact your local HR adviser.  If you are a contractor you should speak with your external contracting/employing company/agency.

You can find further information on the Data Privacy home page:

http://sww.shell.com/ethicsandcompliance/dp/dp.html

If you have any issues, queries or complaints regarding the processing of your personal data please contact us at Privacy-Office-hsoc@shell.com or Shell Group Chief Privacy Officer at Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.

If you are unsatisfied with the handling of your personal data by Shell, then you have the right to lodge a complaint to your the Personal Information Protection Commission whose address is 4^th floor, Government Complex, (03171) 209, Sejong-daero, Jongno-gu, Seoul, Korea. Please visit http://www.pipc.go.kr/ for more information.

Please refer to Tthe Personal Information Protection Commission for further details.

This Privacy Notice may be changed over time. Should there be any inconsistency between the English version and the Korean version of this notice, the former shall prevail.

This Privacy Notice was last updated in September 2018.