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VNENG
RECRUITMENT PERSONAL DATA PROTECTION POLICY

A. GENERAL PROVISIONS

1. Introduction

This Policy is established to comply with relevant laws and regulations on Personal Data protection and is based on the requirements prescribed by the applicable Personal Data protection laws, with the aim of ensuring compliance with Personal Data protection requirements as a foundation for the sustainable business operations of the Group.

This Policy includes provisions that clarify how VNG Group or a Member Company Processes Personal Data in connection with the recruitment activities and other recruitment-related activities of VNG Group or a Member Company (including but not limited to recruitment promotion activities and competitions conducted as part of recruitment promotion programs), issued by the Group CEO from 26/08/2026, and replaces the Personal Data Privacy Policy Related To Recruitment Activities Of VNG, dated 01/07/2024, and any previously attached appendices (if any).

2. Definitions & Interpretations

Terminology

Definitions/Interpretations

Career Sites

The Group’s official recruitment website at: https://career.vng.com.vn/

Policy

This Recruitment Personal Data Protection Policy.

Company or VNG Group

VNG Group JSC, an enterprise established and operating in accordance with the provisions of Vietnamese law, holds the Enterprise Registration Certificate No. 0303490096, issued for the first time on 09/09/2004.

Member Company (ies)

Any subsidiary or affiliated company within the same group that VNG Group has ownership, control, or influence (whether directly or indirectly) in terms of capital, operations, and business.

Personal Data

 

 

Digital data or information in other forms that identifies or assists the identification of a specific individual, including basic Personal Data ("Basic Personal Data") and sensitive Personal Data ("Sensitive Personal Data"). Personal Data, once de-identified, is no longer considered Personal Data.

Basic Personal Data

1. Surname, middle name, and given name at birth; other names (if any);

 

2. Date of birth; date of death or missing;

 

3. Gender;

 

4. Place of birth; place of birth registration; place of permanent residence registration; place of temporary residence registration; current place of residence; hometown; contact address;

 

5. Nationality;

 

6. Images of the individual;

 

7. Phone number; personal identification number; passport number; driver’s license number; vehicle registration plate number;

 

8. Marital status;

 

9. Information on family relationships (parents, children, spouse);

 

10. Information on the individual’s digital accounts;

 

11. Other information associated with a specific individual or capable of identifying a specific individual, other than Sensitive Personal Data.

Sensitive Personal Data

1. Data revealing racial origin or ethnic origin;

 

2. Opinions on politics, religion, and belief;

 

3. Information on private life, personal secrets and family secrets;

 

4. Health status;

 

5. Biometric data and genetic characteristics;

 

6. Data revealing an individual’s sexual life or sexual orientation;

 

7. Data on crimes and violations of laws collected and stored by law enforcement agencies;

 

8. Location data of individuals determined through positioning services;

 

9. Login names and passwords for access to individuals’ electronic identification accounts; images of ID cards, citizen ID cards, or 9-digit ID cards;

 

10. Login names and passwords for access to bank accounts; bank card information; data on transaction history of bank accounts; financial and credit information and other information relating to financial activities and transaction history, securities, and insurance of clients at credit institutions, foreign bank branches, intermediary payment service providers, securities institutions, insurers, and other authorized organizations;

 

11. Data monitoring behavior and activities related to the use of telecommunications services, social networks, online communication services, and other services in cyberspace;

 

12. Other personal data that are required by law to be kept confidential or to which strict confidentiality measures must be applied.

De-identification

The process of altering or deleting information to create new data that can neither be determined nor assist in the identification of a specific individual.

SOP(s)

(Standard Operating Procedure(s))

A document issued to specify principles, standardized step-by-step procedures, roles and responsibilities, controls, and operational requirements for performing a process consistently, efficiently, safely, and in compliance with the Group’s regulations and the relevant applicable laws.

Consent

 

The permission given by the Personal Data Subject for the Processing of their Personal Data under the separate Consent form prepared by the Group and voluntarily confirmed by the Personal Data Subject for each purpose of Personal Data Processing.

Group

This includes VNG Group, all Member Companies, and the branches in all countries.

Recruitment

 

The process of searching for, attracting, evaluating, and selecting individuals with the capabilities, professional qualifications, and qualities suitable to take on job positions at VNG Group and/or a Member Company.

Personal Data Processing/Process(es) Personal Data or Processing

Activities impacting Personal Data, including one or more of the following: collection, analysis, summary, encryption, decryption, modification, deletion, destruction, De-identification, provision, disclosure, transfer of Personal Data, and other activities impacting Personal Data.

Candidate

 

 

A person who is undergoing the recruitment process for job positions at VNG Group or a Member Company via the Career Sites or other recruitment channels of the Group. In this Policy, the Candidate is the Personal Data Subject, being the person to whom the Personal Data relates for the recruitment purposes of the Group.

B. DETAILED CONTENT

1. Legal Basis For Personal Data Processing

The Candidate understands that providing Personal Data is necessary for VNG Group or a Member Company to assess the Candidate’s suitability for the position applied for, and, if successful, to facilitate the Candidate’s working or cooperation process with VNG Group or a Member Company. Subject to the Candidate’s Consent, VNG Group or a Member Company undertakes to Process only the Personal Data necessary for each purpose listed in this Policy and in accordance with the Consent selected by the Candidate.

2. List Of Personal Data Processed By VNG Group Or A Member Company

      2.1  Within the scope of recruitment activities, the Basic Personal Data that may be processed includes:

              2.1.1  Surname, middle name, and given name at birth; other names (if any);

              2.1.2  Date of birth;

              2.1.3  Gender;

              2.1.4  Residence information (including place of permanent residence, place of temporary residence, current place of residence, hometown, and contact address);

              2.1.5  Nationality;

              2.1.6  Marital status;

              2.1.7  Phone number;

              2.1.8  Email address;

              2.1.9  Content, images, audio, and video of the individual provided to VNG Group or a Member Company;

              2.1.10  Work history/experience;

              2.1.11  Academic and education history information;

              2.1.12  Information on relevant degrees and certificates;

              2.1.13  Other Personal Data contained in and collected during the Candidate’s job application process, including the Candidate’s Personal Data and/or the Personal Data of work references, persons referring the Candidate to VNG Group or a Member Company (if any), and/or the Personal Data of the Candidate’s family members (if any), and related documents, including any referral information provided to VNG Group or a Member Company;

              2.1.14  Results of assessments, evaluations, or other reviews carried out during the recruitment process.

      2.2  In certain cases, Sensitive Personal Data will be Processed, including the following information:

              2.2.1  Information on health status contained in health examination reports;

              2.2.2  Information contained in judicial record reports/criminal record certificates provided by the Candidate (if any).

3. When VNG Group Or A Member Company Processes Personal Data

VNG Group or a Member Company Processes the Personal Data provided by the Candidate as part of the Group’s recruitment process. With the Candidate’s Consent, VNG Group or a Member Company may Process Personal Data in the following cases:

      3.1  When the Candidate applies via the Career Sites;

      3.2  When the Candidate submits any application or application form, including, but not limited to, registration forms or other forms relating to any job posting of the Group;

     3.3  When the Candidate interacts with VNG Group or a Member Company, such as by telephone, online chat applications, face-to-face meetings, interviews, social media platforms, letters or emails, or via websites;

     3.4  When the employer, recruitment agency, or other third parties refer a Candidate applying to VNG Group or a Member Company and submit any documents on behalf of the Candidate, in which case VNG Group or a Member Company understands that the Candidate has given the necessary approval to such third parties to allow them to provide the relevant Personal Data to VNG Group or a Member Company;

      3.5 When the Candidate provides relevant documents and information while interacting with VNG Group or a Member Company, or information that the Candidate has published publicly;

      3.6 When the Candidate provides VNG Group or a Member Company with an assessment or feedback from a survey; or

      3.7  When the Candidate sends their Personal Data to VNG Group or a Member Company for any reasons.

4. Consent For Personal Data Processing

      4.1  By applying for any job posting of the Group on the Group’s official recruitment website or on other affiliated recruitment platforms of the Group, and/or registering an account on the Group’s official recruitment website, and/or disclosing any Personal Data to VNG Group or a Member Company, VNG Group or a Member Company will firstly obtain the Candidate’s Consent and thereafter Process Personal Data, including: collecting, using, storing, transferring, disclosing, … and publishing such Personal Data to the relevant parties in accordance with this Policy and applicable law.

      4.2  The Candidate may withdraw their Consent where there is doubt as to the scope or purpose of the Processing of Personal Data or as to the accuracy of the Personal Data. Upon a request for withdrawal of Consent, VNG Group or a Member Company undertakes to duly consider the request and carry out the Processing in accordance with the order and procedures prescribed by law. Please note that the withdrawal of Consent does not affect the lawfulness of the Personal Data Processing activities carried out prior to the time of withdrawal.

5. Purposes Of Personal Data Processing

VNG Group or a Member Company may Process the Candidate’s Personal Data for one or more of the following purposes:

      5.1  To screen, assess, and evaluate the Candidate’s suitability for the position applied for;

      5.2  To contact and further discuss the application, invite the Candidate to interviews, follow up on the post-interview and recruitment process, provide feedback from VNG Group or a Member Company, notify interview results, and extend job offers;

      5.3  To verify identity, information for entering into contracts/agreements, conduct background checks and/or judicial record checks to the extent required or permitted by applicable law;

      5.4  To provide the Candidate with other job opportunities that are consistent with the Candidate’s Personal Data and that VNG Group or a Member Company believes may be of interest to the Candidate;

      5.5  To assess the Candidate’s experience;

      5.6  To carry out statistics, to report, to process in compliance with the Group’s SOPs and applicable laws, control & risk management, and internal investigations;

      5.7  To notify amendments, supplements, changes/updates to the information security and personal data protection policy of VNG Group or a Member Company;

      5.8  To share Personal Data in accordance with Section B.8 of this Policy; and

      5.9  Any other purpose notified by VNG Group or a Member Company at the time of seeking the Candidate’s Consent.

6. Methods Of Personal Data Processing

      6.1  The Candidate’s Personal Data will be Processed strictly for the purposes specified in Section B.5 of this Policy, in accordance with applicable laws, using paper-based, electronic, or technology-enabled telecommunications means. VNG Group or a Member Company may also use automated (or equivalent) data Processing methods involving the Candidate’s Personal Data where necessary to enhance the job search and job matching process. In all cases, VNG Group or a Member Company will only use methods of Personal Data Processing that ensure the safety and security of Personal Data in accordance with applicable laws.

      6.2  By disclosing Personal Data to VNG Group or a Member Company, the Candidate warrants that none of such Personal Data is:

              6.2.1  State secrets in accordance with Vietnamese law, the collection or disclosure of which is generally prohibited, unless approved by competent authorities;

              6.2.2  Family secrets of the Candidate’s family, which the Candidate has not been authorized to disclose to VNG by all members of the family; and

              6.2.3  Business secrets of other companies or legal entities; or

              6.2.4  Personal Data of other persons which the Candidate has no lawful right to disclose or provide.

7. Commencement & Termination Of Personal Data Processing

      7.1  Only upon obtaining Consent will the Processing of Personal Data commence, when VNG Group or a Member Company obtains the Candidate’s Personal Data in the manner described in this Policy.

      7.2  Unless otherwise required by applicable laws from time to time, the Candidate’s Personal Data will be retained for as long as necessary to fulfil the purposes specified in Section B.5 of this Policy, which is currently up to 10 years from the date on which VNG Group or a Member Company most recently receives the Candidate’s application, unless otherwise requested by the Candidate.

      7.3  Upon expiry of the applicable data retention period (if any), or when it is no longer necessary to retain the Candidate’s Personal Data, or in other circumstances as required by applicable laws, VNG Group or a Member Company will cease Processing and take appropriate measures to delete the Candidate’s Personal Data and notify the Candidate of such deletion (where practicable), unless otherwise required by applicable laws.

8. Personal Data Sharing & Transfer

      8.1  VNG Group or a Member Company may disclose and share certain Personal Data of the Candidate with the following organizations during the recruitment process:

              8.1.1  VNG Group may share the Candidate’s Personal Data with a Member Company, and vice versa, for the purpose of carrying out processes such as Group-wide reporting or making decisions on selection or promotion;

              8.1.2  Personal data processing party: VNG Group or a Member Company may engage service providers to support the Processing of Personal Data. Such third parties may be granted access to, or may merely store, the Candidate’s Personal Data, but VNG Group or a Member Company contractually ensures that all such third parties Process the Candidate’s Personal Data in a safe manner and ensure confidentiality;

              8.1.3  Regulators & Government Authorities (e.g. the tax authority or the social insurance authority): VNG Group or a Member Company may be required to share Personal Data pursuant to an order or request from a court, parties to legal proceedings, or regulators & government authorities; to comply with statutory requirements; or to fulfil its obligations to regulators & government authorities.

      8.2  VNG Group or a Member Company will not transfer the Candidate’s Personal Data to any third party for use in their marketing activities.

9. Personal Data Of Children

VNG Group or a Member Company does not Process or maintain any Personal Data or information from any person under 16 years of age, nor is any part of the Group’s Career Sites directed at minors under 16 years of age. VNG Group or a Member Company will remove and/or delete any Personal Data which VNG Group or a Member Company believes to have been submitted by any child under 16 years of age.

10. Rights & Obligations Of The Personal Data Subject

      10.1  Refusal to give and/or withdrawal of Consent to the Processing purposes set out in Sections B.5.1 to B.5.8 means that VNG Group or a Member Company will not be able to proceed with the recruitment, and the Candidate accordingly acknowledges that they will not proceed with any further transaction and/or action with VNG Group or a Member Company. The Processing purposes set out in Sections 5.4 and 5.5 are intended to provide additional value to the Candidate, and the Candidate has the right to choose whether or not to permit the Personal Data Processing for such purposes without materially affecting the recruitment.

      10.2  VNG Group or a Member Company acknowledges and duly respects the rights that the Personal Data Subject may have under applicable laws. Upon receiving a request from the Personal Data Subject relating to the Personal Data Processing, VNG Group or a Member Company will duly consider such request and carry it out in accordance with the order/procedures prescribed by applicable law, while responding to the Candidate in a timely manner.

      10.3  The Candidate shall accordingly duly comply with the following obligations of the Personal Data Subject, including:

              10.3.1  To protect their own Personal Data;

              10.3.2  To respect and protect the Personal Data of others;

              10.3.3  To adequately and accurately provide their Personal Data in accordance with the law, agreements, or upon consenting to the Processing of their Personal Data;

              10.3.4  To comply with Personal Data protection laws and participate in the prevention of and fight against acts infringing upon Personal Data.

      10.4  When exercising their rights and fulfilling their obligations, the Candidate shall fully comply with the following principles:

              10.4.1  Complying with the law; performing the obligations of the Personal Data Subject under agreements and/or Consent. The exercise of the rights and obligations of the Personal Data Subject must be aimed at protecting the legitimate rights and interests of such Personal Data Subject;

              10.4.2  Refraining from causing difficulty to or obstructing the exercise of the legal rights and obligations of the Personal Data controlling party, the Personal Data Processing and controlling party, and the Personal Data Processing party;

              10.4.3  Refraining from infringing upon the legitimate rights and interests of the State and other agencies, organizations, and individuals.

11. Contact

      11.1  If the Candidate has any question, query, feedback, complaint, or request concerning their Personal Data, please contact VNG Group or a Member Company by email at hrteam@vng.com.vn.

      11.2  VNG Group or a Member Company will handle the Candidate’s request in accordance with the provisions of this Policy, the Group’s SOPs in force from time to time, and the applicable laws.