Privacy Notice – Applicant

Notice Date: 30 June 2026

We are committed to protecting your privacy when dealing with your personal information. This privacy notice is prepared in accordance with the Personal Data (Privacy) Ordinance (the “Ordinance”) and also operates as the Personal Information Collection Statement which we will provide, or make available, to you on or before the collection of your personal information by us.

By providing us with your personal information you consent to us collecting, using and disclosing your personal information as outlined in this privacy notice.

IMPORTANT: The provision of personal information is voluntary. Failure to provide sufficient information, however, may result in us being unable to consider your application. Please read this Privacy Notice carefully.

If you have any questions about how we handle your information, please contact us at:

Bupa International Limited: po@bupa.com.hk

Quality HealthCare Group: po@qhms.com

Contents

1. Information about us
2. What this privacy notice covers
3. How we collect personal information
4. Types of personal information
5. What we use your personal information for
6. Sharing your information
7. How long we keep your personal information
8. Use of Cookies
9. Use of AI And Automation Technologies
10. Your rights

1. Information about us

1.1 In this privacy notice, ‘we’, ‘us’, ‘our’ and ‘Company” mean Bupa International Limited, Bupa (Asia) Limited, Horizon Health & Care Limited, Blua (Asia) Services Limited, Quality HealthCare Professional Services Limited, Quality Healthcare Dental Services Limited, Quality HealthCare TPA Services Limited and Quality HealthCare Medical Centre Limited and may be extended to other companies of Bupa in the Hong Kong Special Administrative Region (“Bupa Hong Kong”), as deemed appropriate.

1.2 For the purposes of this privacy notice, “Group Company” means the Company and its holding companies, branches, subsidiaries, representative offices and affiliates, wherever situated, and any one of them. Affiliates include branches, subsidiaries, representative offices and affiliates of the Company’s holding companies, wherever situated (collectively, the “Group”).

1.3 Please contact your recruitment officer for information about which Bupa Hong Kong company collects and uses your personal information during the recruitment process. Should you be successfully employed by us as an employee, your personal information will be handled in accordance with our employee data privacy notice.

2. What this privacy notice covers

2.1 This privacy notice is for people who apply for a role with us. In this privacy notice, references to ‘work’ include our permanent and temporary employment, as well as agency work, independent contractor work, traineeships, internships, vacation schemes, work experience placements and volunteering employees. We may give you further privacy information, if necessary, for specific reasons.

2.2 By entering personal information on any of our websites, recruitment portals, and/or applying for positions with us, you are consenting to the transfer of your personal information between our Group companies and/or to third parties throughout the world as necessary to progress your application and, should your application be successful, to administer your personnel record.

3. How we collect personal information

3.1 We collect personal information from you and from certain the people and organisations (for example, recruitment agents and referees).

3.2 You must provide all relevant personal information so that we can meet our obligations, you can enjoy the benefits that we offer, and we can manage our relationship with you properly. If you do not do so, these outcomes may not be possible.

3.3 If you provide us with information about other people (for example, your referees), you must make sure that they know you are doing this and do not object to you giving us their information. You should also make them aware of this privacy notice.

3.4 We collect personal information from you through interactions with us, including by phone, by email, by instant messenger (for example, WhatsApp) and/or through our websites, on our apps, by post, by uploading your cover letter and resume, by taking part in assessments (for example, online personality tests and presentation exercises in group interviews), by filling in application or other forms, on social media, digital platforms, or face-to-face (for example, in interviews).

3.5 We also collect personal information about you by monitoring your access to our premises (such as from CCTV, door entry systems and workplace health screening), and your use of our devices and systems.

3.6 We use an applicant tracking system (“ATS”), powered by Workable, to assist in the management and administration of our recruitment process. The ATS helps us to:

1. receive and manage job applications;
2. communicate with you in the recruitment process; and
3. schedule interviews and manage recruitment workflows.

3.7 From the information we collect about you, we may also derive or generate further information such as job candidate profiles.

3.8 We collect your personal information from people and organisations such as:

1. your agents (for example, a recruitment officer or legal representative);
2. your referees (for example, your former employers);
3. if you have been referred for a position by a Bupa employee, the Bupa employee who referred you;
4. any service providers who work with us in relation to your employment (for example, selection companies and providers of online assessments);
5. service providers, such as LinkedIn, who, with your permission, share your account and profile information in order to pre-fill our online application forms;
6. your parent or guardian, if you are under 18 years of age;
7. doctors, other clinicians and health-care professionals, hospitals, clinics and other health-care providers, to help with workplace health and safety;
8. our agents (for example, our legal representatives if we are involved in legal proceedings against you);
9. credit-reference agencies, fraud-detection agencies, criminal-history reference agencies, background-screening agencies, if we need to carry out relevant checks (we will tell you at the time if we collect information from you to carry out these checks);
10. government departments (for example, the Inland Revenue Department); and
11. publicly available sources, such as your LinkedIn profile and other public social media activity reviewed during recruitment to understand your professional background and qualifications, as well as any published work relevant to the role, including research or academic articles.

4. Types of personal information

4.1 We will only collect information that is necessary for the purposes for which it will be used. We process the following types of personal information about you and (where this applies) your dependants.

1. Standard personal information (for example, information we use to contact you, identify you or manage our relationship with you.)
2. Sensitive personal information (for example, national identifiers, health information in connection with medical or carer’s leave, health information in connection with workplace health screening, information about your nationality and criminal-offence information).

4.2 Standard personal information includes:

1. contact information (for example, your name, username, residential and correspondence addresses, email address and phone numbers);
2. the country you live in, your age, your gender, your date of birth, your nationality, your right to work in Hong Kong;
3. information about your employment (for example, the date you were hired, the dates of any promotions, the dates and details of your resignation or termination performance appraisals (if this applies), records of training, investigation and disciplinary matters);
4. details of your previous work and your education, professional certificates and registrations, and other information from your resume;
5. financial details (for example, your payslips and bank account number);
6. the results of any background checks (not including criminal-history checks) we have carried out on you;
7. photographs and videos from our CCTV systems; and
8. the times when you enter and leave our offices (which we collect from our door entry systems).

4.3 Sensitive personal information includes:

1. your national identifiers (for example, your Hong Kong Identification number or passport number);
2. information about your physical or mental health (this information may be included in applications forms, or this information may be included in sickness records, notes and reports about your health and any treatment and care you have received or need, and medical certificates, or information we collect during workplace health screening (such as using thermal imaging or checking your temperature), or, where required for your role, vaccination history information);
3. information about your nationality and ethnic origin (this information may be included in application forms, or you may choose to reveal it during your employment to support diversity and inclusion initiatives); and
4. information about your criminal record (you may choose to tell us about your criminal-history in your application. Depending on your role, we may also need to carry out a criminal-history check and we will tell you if we plan to carry out a check).

5. What we use your personal information for

5.1 We may use, store, process, transfer, disclose or share your personal information for the following purposes from time to time:

1. manage the recruitment process and our relationship with you, our business and people and organisations who provide services for us;
2. ensure that you are fit and proper to fulfil the requirements of the role you are applying for to enable us to protect our customers, patients, employees, business reputation and assets;
3. manage and personalise your interactions with our recruitment portals and websites;
4. communicate with you through phone, email, instant messenger (for example, WhatsApp) and/or other means that become available from time to time to respond to your application, queries, requests and use of our recruitment portals;
5. invite you to apply for a position that you have been referred for by a Bupa employee;
6. carry out business activities related to recruitment including administration, quality assurance, risk management and information services;
7. maintain proper and secure operation of our recruitment portals and related systems from time to time;
8. protect our (or our customers’ or other people’s) rights, property or safety, including to maintain a safe working environment and identify any potential conflict of interest;
9. administer recruiting surveys, programs, and events, and for related services;
10. performing any functions and activities related to the recruitment process, without limitation, audit, reporting, market research, identity verification, data matching, research, automated decision making processes (including profiling) and data analytics (please see further details in paragraph 9 below), statistical analysis, and insurance/reinsurance arrangements;
11. carry out our obligations and exercise rights under legislation (for example, we process health and disability information so that we can understand any reasonable adjustments we might need to make for you during the recruitment process or if you come to work for us, and we process information about your race, ethnic origin, religion or philosophical beliefs to help us monitor equal opportunities);
12. fulfil any other purposes directly related to recruitment and employment;
13. exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the people and organisations we work with;
14. take part in, or be the subject of, any sale, merger or takeover of all or part of the Bupa Group business; and
15. contact you about future roles that may be of interest to you.

6. Sharing your information

6.1 We may transfer your personal information inside or outside the Hong Kong Special Administrative Region (“Hong Kong”), for the purposes set out in this privacy notice, with the following classes of transferees:

1. other members and/or brands of the Bupa Group;
2. any of our employees or agents who are involved in the recruitment process;
3. any Bupa employee who referred you for a role, if you apply for that role on the basis of that referral. The Bupa employee who referred you will be able to view the progress status of your application;
4. doctors, clinicians and other health-care professionals, hospitals, clinics and other health-care providers to help with workplace health and safety;
5. our agents (for example, our legal representatives, translators, interpreters and tax advisers in line with the law);
6. suppliers who help deliver products or services on our behalf, or who we have engaged by us in relation to recruitment and related activities;
7. any corporate clients you provide services to on-site, if your role involves this;
8. people or organisations we have to, or are allowed to, share your personal information with by law or as requested by authorities (for example, for fraud-prevention or safeguarding purposes);
9. our regulators;
10. governmental bodies (for example, the Inland Revenue Department);
11. industry recognised bodies;
12. the Courts;
13. the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order;
14. if this applies, potential buyers of all or part of our business;
15. any party to whom you have consented the disclosure of your personal information; and
16. where otherwise required by applicable law or regulations.

6.2 If we share your personal information, we will make sure appropriate protection is in place in line with data-protection laws.

6.3 If you are located outside Hong Kong, by submitting your application to us or by accessing or continuing to use any of our recruitment services, products, digital portals, you give explicit consent to your personal information being received, collected, stored, used, processed, disclosed, transmitted and transferred outside your place of residence or country in accordance with the protections described in this privacy notice.

7. How long we keep your personal information

7.1 In general, we will keep your information for the period needed to meet our legal responsibilities. If your application is successful, we will keep your personal information for seven years after the date you leave your employment. If your application is unsuccessful, we will keep your information for 24 months from the date of receiving your application.

7.2 However, there may be circumstances where we must keep your personal information for longer. For example, if there is an ongoing tribunal, court or other types of proceedings in relation to you, we would keep your information until the end of those proceedings and any possible appeals, and the end of any relevant claims periods.

7.3 We use the following criteria to help us decide how long we need to keep your personal information for.

1. Whether you take up employment or another arrangement with us, and the length of that employment or arrangement.
2. How long it is reasonable to keep records to show we have met the obligations we have to you and by law.
3. Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations.
4. Any time limits for making a claim.
5. Any tribunal, court or other relevant proceedings that apply.
6. How long it would be reasonable to expect you to reapply for a job or to ask for a reference.

7.4 At the end of the period worked out using the above criteria, we will securely and permanently delete the personal information in your file.

7.5 We are committed to keeping your information secure and will store it in line with our enterprise security policy. We will take all practicable steps to protect your personal information against unauthorised or accidental access, processing, erasure, loss or use. This includes implementing a range of digital and physical security measures. In addition, we will restrict access to your personal information to those properly authorised to have access.

7.6 Our online portals may have links to other external websites over which we do not have control. You are advised to refer to the privacy policies of these websites for more information.

8. Use of Cookies

8.1 When you use our websites, applications and/or online portals, we and third-party companies collect information by using cookies and other technologies such as pixel tags (for simplicity we refer to all such technologies as "cookies"). The updated version of the Cookies Policy is available for review from our corporate website at here. You can also control, block, or delete cookies through your web browser settings, usually found under "settings" on your chosen browser.

8.2 To find out more about cookies please visit aboutcookies.org or allaboutcookies.org.

9. Use of AI And Automation Technologies

9.1 Like many businesses, we may use artificial intelligence (AI) and other automation technologies to facilitate operational efficiency, fairness and consistency in our recruitment process

9.2 Some of the ways for using these technologies include:

1. Optical Character Recognition (OCR) technology may be used to automate data extraction from paper and electronic documents. This reduces waiting times for processing the applications.
2. ATS, powered by Workable, to manage and administer our recruitment process. This reduces manual administrative tasks.

9.3 All applications are reviewed by our Talent Acquisition team to ensure fair and thoughtful consideration.

10. Your rights

10.1 In accordance with the terms of the Ordinance, you have a right to make the following requests relating to the information we hold about you.

1. To check whether we hold personal information relating to you and to access such personal information;
2. To require us to correct any personal information relating to you which is inaccurate; and
3. To ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.

10.2 These rights may not apply in all cases. If we are not able to meet your request, we will explain why. If you make a request, we will ask you to confirm your identity if we need to, and to provide information that helps us to understand your request better. If you would like more information about your rights, or to exercise any of your rights, or to access and obtain the latest version of this privacy notice, please contact us by writing to the email address available at the beginning of this privacy notice.

10.3 In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for the processing of any personal information access or correction request.

10.4 In case of discrepancies between the English and Chinese versions of this Statement, the English version shall prevail.