Data Privacy Notice

Data Privacy Notice Template for Hong Kong

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Key Requirements PROMPT example:

"I need a Data Privacy Notice for my Hong Kong-based e-commerce platform that will launch in March 2025, with specific focus on cross-border data transfers to mainland China and the use of cookies for personalized marketing."

Document background

A Data Privacy Notice is a mandatory document for organizations operating in Hong Kong that collect, process, or handle personal data. This document is required under the Personal Data (Privacy) Ordinance (PDPO) and must be provided to data subjects to ensure transparency in data processing activities. The notice should be issued when personal data is collected or before it is used for any purpose. It must detail the types of data collected, purposes of collection, retention periods, third-party sharing, and data subject rights. The document needs regular updates to reflect changes in data handling practices or regulatory requirements, particularly given Hong Kong's evolving data protection landscape and its position as an international business center. It serves both as a compliance tool and as a trust-building mechanism with stakeholders.

Suggested Sections

1. Introduction: Overview of the organization and purpose of the privacy notice

2. Scope of the Privacy Notice: Who the notice applies to and what activities it covers

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

4. Methods of Collection: How personal data is collected (direct, indirect, automated means)

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

6. Data Storage and Security: How personal data is stored and protected

7. Data Retention: How long personal data is kept and criteria for retention periods

8. Data Sharing and Transfers: Third parties with whom data is shared and circumstances of sharing

9. Data Subject Rights: Rights under the PDPO including access, correction, and deletion

10. Contact Information: How to contact the organization regarding privacy matters

11. Updates to Privacy Notice: How changes to the notice will be communicated

Optional Sections

1. Direct Marketing: Required if personal data is used for direct marketing, including opt-in/opt-out procedures

2. Cookies and Tracking: Required for websites using cookies or similar tracking technologies

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

4. Cross-border Transfers: Required if personal data is transferred outside Hong Kong

5. Biometric Data Processing: Required if collecting or processing biometric data

6. Automated Decision Making: Required if using automated processing to make decisions about individuals

7. Special Categories of Data: Required if collecting sensitive personal data like health information

Suggested Schedules

1. Schedule 1: Categories of Personal Data: Detailed list of all personal data categories collected, organized by type

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

3. Schedule 3: Retention Periods: Detailed retention periods for different categories of personal data

4. Appendix A: Cookie Policy: Detailed information about cookies and other tracking technologies used

5. Appendix B: Technical and Organizational Measures: Details of security measures implemented to protect personal data

Authors

Alex Denne

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

alex.den.21@genieai.co

Relevant legal definitions

Clauses

Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Education

Professional Services

Retail

Insurance

Telecommunications

Manufacturing

Real Estate

Hospitality

Transportation

Media and Entertainment

Non-profit Organizations

Government and Public Sector

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Data Protection

Privacy

Corporate Governance

Operations

Customer Service

Human Resources

Marketing

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Compliance Manager

Legal Counsel

Privacy Manager

Information Security Manager

Risk Manager

IT Director

Chief Information Security Officer

Chief Technology Officer

Chief Legal Officer

Compliance Officer

Privacy Analyst

Data Protection Specialist

Corporate Secretary

General Counsel

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