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October 28 2013

Hong Kong Issues Clearer Guidance on Privacy Notices

The Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD) has issued a new guidance note on preparing Personal Information Collection Statements (PICS) and Privacy Policy Statements (PPS). The guidance note is intended to help organizations prepare clear and informative privacy notices in order to comply with the requirements under the Personal Data (Privacy) Ordinance and the Data Protection Principles (DPPs). Broadly, a PICS statement sets out how a data subject 's personal data will be collected and used by the organization. A PPS statement - which often incorporates a PICS - should also set out the organization 's policies on data retention, data security, and how it will deal with requests for data access and correction. The PICS and PPS statements are required under DPP1 (which requires a data user to inform a data subject of the purpose and manner of collection of their personal data) and DPP5 (which requires a data user to take steps to ensure that a data subject can ascertain the personal data policies and practices of the data user), respectively. The publication of this guidance note by the PCPD now, perhaps suggests that in Hong Kong at least there is a concern with the availability and clarity of PICS and PPS statements.