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Data protection policy
1.1Everyone has rights with regard to the way in which their personal data in handled. During the course of our activities we will collect, store and process personal data about our service providers, users and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
1.2Data users are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy may result in disciplinary action.
2.ABOUT THIS POLICY
2.1The types of personal data that OK Care Limited (“Company“) (We) may be required to handle include information about current, past and prospective service providers, users and others that we communicate with. Refusal to provide such information may deny you access to certain parts of the application or may render us unable to process any application and requests. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Personal Data (Privacy) Ordinance (Cap 486) (“Ordinance”).
2.2This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.
2.3It sets out rules on data protection and the legal conditions that will be satisfied when we obtain, handle, process, transfer and store personal data.
2.4The Data Protection Compliance Manager is responsible for ensuring compliance with the Ordinance and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.
3.DEFINITION OF DATA PROTECTION TERMS
3.1Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
3.2Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. All data subjects have legal rights in relation to their personal information.
3.3Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual, including a name, gender, date of birth, nationality, telephone number, postal address, email address, credit card information, bank account number, educational level, occupation, household income, personal income, details of online transactions, marital status and interests.
3.4Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Ordinance. We are the data controller of all personal data used in our business for our own commercial purposes.
3.5Data users are those of our employees or contractors whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.
3.6Data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. It could include suppliers which handle personal data on the Company’s behalf.
3.7Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
4.DATA PROTECTION PRINCIPLES
Anyone processing personal data must comply with the principles of good practice. These provide that personal data will be:
- Processed fairly and lawfully.
- Processed in an appropriate way.
- Adequate, relevant and not excessive for the purpose.
- Processed in line with data subjects’ rights.
5.FAIR AND LAWFUL PROCESSING
5.1The Ordinance is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.
5.2For personal data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the Ordinance. These include, among other things, the data subject’s consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.
6.PROCESSING FOR LIMITED PURPOSES
6.1In the course of our business, we may collect and process the personal data, including data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
6.2We will only process personal data for the specific purposes specifically permitted by the Ordinance. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.
7.NOTIFYING DATA SUBJECTS
7.1If we collect personal data directly from data subjects, we will inform them about:
- The purpose or purposes for which we intend to process that personal data.
- The types of third parties, if any, with which we will share or to which we will disclose that personal data.
- The means, if any, with which data subjects can limit our use and disclosure of their personal data.
7.2If we receive personal data about a data subject from other sources, we will provide the data subject with this information as soon as possible thereafter.
7.3We will also inform data subjects whose personal data we process that we are the data controller with regard to that data.
8.ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take reasonable steps to destroy, or erase from our systems, all data which is no longer required.
11.PROCESSING IN LINE WITH DATA SUBJECT’S RIGHTS
We will process all personal data in line with data subjects’ rights, in particular their right to:
- Request access to any data held about them by a data controller (see also clause 15).
- Prevent the processing of their data for direct-marketing purposes.
- Ask to have inaccurate data amended (see also clause 9).
- Prevent processing that is likely to cause damage or distress to themselves or anyone else.
12.1We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
12.2We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
12.3We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
- Confidentiality means that only people who are authorised to use the data can access it.
- Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
- Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the Company’s central computer system instead of individual PCs.
12.4Security procedures include:
- Entry controls. Any stranger seen in entry-controlled areas should be reported.
- Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind.
- Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.
- Equipment. Data users must ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
13.TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE HKSAR
13.1We may transfer any personal data we hold to a country outside HKSAR, provided that one of the following conditions applies:
- The country to which the personal data are transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
- The transfer is necessary for one of the reasons set out in the Ordinance, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.
- The transfer is legally required for the establishment, exercise or defence of legal claims.
- The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
13.2Subject to the requirements in clause 12.1 above, personal data we hold may also be processed by staff or contractors operating outside HKSAR who work for us or for one of our suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.
14.DISCLOSURE AND SHARING OF PERSONAL INFORMATION
14.1We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
14.2We may also disclose personal data we hold to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets.
14.3If we are under a duty to disclose or share a data subject’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
15.DEALING WITH SUBJECT ACCESS REQUESTS
Data subjects must make a formal request for information we hold about them. This must be made in writing to the Data Protection Compliance Manager.
16.PERSONAL DATA ACCESS AND REVISION
Data subject may access and check the personal data which is retained by us. If the data user wants to revise the personal data he or she has provided with us, please contact our Data Protection Compliance Manager in writing either by post or email at:
Data Protection Compliance Manager
OK Care Limited
Room 912, 9/F, Melbourne Plaza
33 Queen’s Road Central
17.CHANGES TO THIS POLICY
We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.