Global Privacy Notice for Hong Kong

Global Privacy Notice Template for Hong Kong

A comprehensive privacy notice document governed by Hong Kong law, specifically compliant with the Personal Data (Privacy) Ordinance (PDPO), while incorporating global privacy requirements. This document serves as a transparent declaration of an organization's personal data collection, processing, and protection practices. It addresses both Hong Kong-specific requirements and international privacy standards, making it suitable for organizations operating globally while maintaining Hong Kong as their primary regulatory jurisdiction. The notice includes detailed sections on data subject rights, cross-border transfers, and specific compliance measures required under Hong Kong law.

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What is a Global Privacy Notice?

The Global Privacy Notice is essential for organizations operating internationally while being subject to Hong Kong privacy laws. This document becomes necessary when an organization collects, processes, or handles personal data across multiple jurisdictions. The notice must comply primarily with Hong Kong's Personal Data (Privacy) Ordinance (PDPO) while also addressing requirements from other major privacy regulations. It typically includes comprehensive information about data collection purposes, processing activities, data subject rights, and international transfer mechanisms. The Global Privacy Notice serves as a fundamental transparency tool, helping organizations meet their legal obligations while building trust with data subjects. It should be regularly reviewed and updated to reflect changes in privacy laws, organizational practices, or data handling procedures.

What sections should be included in a Global Privacy Notice?

1. Introduction: Overview of the privacy notice scope and applicability

2. Definitions: Key terms used throughout the privacy notice, including 'personal data', 'processing', 'data subject', etc.

3. Types of Personal Data Collected: Comprehensive list of personal data categories collected and processed

4. Purposes of Collection and Use: Detailed explanation of why personal data is collected and how it will be used

5. Legal Basis for Processing: Legal grounds for processing personal data under relevant laws

6. Data Sharing and Transfers: Information about third-party sharing and international data transfers

7. Data Security Measures: Description of technical and organizational measures to protect personal data

8. Data Retention: Information about how long personal data is kept and deletion policies

9. Your Rights: Explanation of data subject rights under PDPO and other applicable laws

10. Contact Information: Details of the data controller and privacy officer contact information

11. Updates to Privacy Notice: Process for updating the privacy notice and notifying of changes

What sections are optional to include in a Global Privacy Notice?

1. Cookies and Tracking Technologies: Required if the organization uses websites or online tracking tools

2. Direct Marketing: Required if personal data is used for direct marketing purposes under PDPO requirements

3. Children's Privacy: Required if services may be used by or data collected from children

4. Employee Data Processing: Required if the privacy notice covers employee personal data

5. Special Categories of Data: Required if processing sensitive personal data like health information

6. Automated Decision Making: Required if using automated processing or profiling

7. Local Privacy Requirements: Required if specific jurisdictional variations need to be addressed

What schedules should be included in a Global Privacy Notice?

1. Schedule 1: Detailed Data Processing Activities: Comprehensive list of processing activities, purposes, and legal bases

2. Schedule 2: Third Party Recipients: List of categories of third parties with whom data is shared

3. Schedule 3: International Transfer Mechanisms: Details of safeguards for international data transfers

4. Schedule 4: Cookie List: Detailed list of cookies and tracking technologies used

5. Schedule 5: Country-Specific Privacy Requirements: Jurisdiction-specific privacy requirements and variations

6. Appendix A: Data Subject Request Form: Standard form for submitting data subject rights requests

7. Appendix B: Security Measures: Detailed description of security measures and protocols

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Jurisdiction

Hong Kong

Publisher

Genie AI

Cost

Free to use
Relevant legal definitions
Clauses
Relevant Industries

Financial Services

Healthcare

Technology

Retail

E-commerce

Education

Professional Services

Manufacturing

Telecommunications

Insurance

Real Estate

Travel and Hospitality

Media and Entertainment

Non-profit Organizations

Government and Public Sector

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Human Resources

Marketing

Operations

Customer Service

Data Protection

Internal Audit

Corporate Communications

Digital

Product Development

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Legal Officer

Chief Compliance Officer

Privacy Manager

Legal Counsel

Compliance Manager

Information Security Officer

Risk Manager

IT Director

Chief Information Officer

Chief Technology Officer

HR Director

Marketing Director

Operations Manager

Industries
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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