This General Privacy Notice serves as a fundamental document for organizations operating in Hong Kong that collect, process, or handle personal data. It is designed to comply with the Hong Kong Personal Data (Privacy) Ordinance (PDPO) and guidelines issued by the Privacy Commissioner for Personal Data (PCPD). The document is essential for establishing transparency in data handling practices and maintaining compliance with Hong Kong's data protection regime. It should be implemented by organizations before they begin collecting personal data and should be regularly reviewed and updated to reflect changes in data processing activities or regulatory requirements. The notice includes mandatory disclosures about data collection purposes, data subject rights, and data handling practices, while also addressing specific requirements such as direct marketing consent and cross-border data transfers where applicable.
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1. Introduction: Overview of the organization and scope of the privacy notice
2. Definition of Personal Data: Clear explanation of what constitutes personal data under the PDPO and in the context of the organization's operations
3. Types of Personal Data We Collect: Comprehensive list of personal data categories collected by the organization
4. How We Collect Your Personal Data: Description of all data collection methods and sources
5. Purposes of Data Collection and Use: Detailed explanation of why personal data is collected and how it will be used
6. Data Storage and Security: Information about how personal data is stored and protected
7. Data Retention: Explanation of how long different types of personal data are retained
8. Your Rights: Description of data subject rights under the PDPO and how to exercise them
9. Contact Information: Details of how to contact the organization regarding privacy matters
1. Direct Marketing: Required if personal data is used for direct marketing purposes, detailing opt-in/opt-out procedures
2. Cross-border Data Transfers: Required if personal data is transferred outside of Hong Kong
3. Cookies and Tracking Technologies: Required for organizations operating websites or online services
4. Children's Privacy: Required if services may be accessed by or data collected from children
5. Third-Party Service Providers: Required if third parties process personal data on behalf of the organization
6. Automated Decision Making: Required if the organization uses automated processing to make decisions about individuals
1. Schedule 1: Types of Personal Data: Detailed categorization of all personal data collected, allowing for easy updates as data collection practices change
2. Schedule 2: Third-Party Recipients: List of categories of third parties who receive personal data, facilitating updates as partnerships change
3. Schedule 3: Cookies List: Detailed list of cookies and similar technologies used, with descriptions and purposes
4. Schedule 4: Data Retention Periods: Specific retention periods for different categories of personal data
Relevant legal definitions
Personal Data
Processing
Data Subject
Data User
Data Processor
Sensitive Personal Data
Cookie
Direct Marketing
Consent
Third Party
Data Access Request
Data Correction Request
Log Data
IP Address
Privacy Commissioner
PDPO
Automated Processing
Cross-border Transfer
Data Retention Period
Anonymization
Pseudonymization
User Device
Service Provider
Website
Mobile Application
Marketing Communications
Opt-out
Privacy Policy
Data Protection Principles
Data Breach
Processing
Data Subject
Data User
Data Processor
Sensitive Personal Data
Cookie
Direct Marketing
Consent
Third Party
Data Access Request
Data Correction Request
Log Data
IP Address
Privacy Commissioner
PDPO
Automated Processing
Cross-border Transfer
Data Retention Period
Anonymization
Pseudonymization
User Device
Service Provider
Website
Mobile Application
Marketing Communications
Opt-out
Privacy Policy
Data Protection Principles
Data Breach
Clauses
Data Collection
Purpose Limitation
Data Use
Data Storage
Data Security
Data Retention
Data Subject Rights
Consent
Direct Marketing
Cross-border Transfer
Third Party Sharing
Data Access
Data Correction
Website Tracking
Cookie Usage
Children's Privacy
Data Breach Notification
Compliance
Contact Information
Updates to Privacy Notice
Accountability
Marketing Communications
Technical Security
International Data Transfers
Automated Processing
Purpose Limitation
Data Use
Data Storage
Data Security
Data Retention
Data Subject Rights
Consent
Direct Marketing
Cross-border Transfer
Third Party Sharing
Data Access
Data Correction
Website Tracking
Cookie Usage
Children's Privacy
Data Breach Notification
Compliance
Contact Information
Updates to Privacy Notice
Accountability
Marketing Communications
Technical Security
International Data Transfers
Automated Processing
Relevant Industries
Financial Services
Healthcare
Retail
Technology
E-commerce
Education
Professional Services
Manufacturing
Real Estate
Telecommunications
Insurance
Tourism and Hospitality
Transportation and Logistics
Media and Entertainment
Non-profit Organizations
Relevant Teams
Legal
Compliance
Information Technology
Information Security
Risk Management
Marketing
Human Resources
Customer Service
Operations
Digital
Data Protection
Privacy
Relevant Roles
Chief Privacy Officer
Data Protection Officer
Legal Counsel
Compliance Manager
Information Security Manager
Risk Manager
IT Director
Chief Technology Officer
Marketing Director
Operations Manager
Human Resources Director
Customer Service Manager
Digital Operations Manager
Chief Information Officer
Privacy Analyst
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