The Client Privacy Policy is a crucial document required for compliance with Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and guidelines issued by the Privacy Commissioner for Personal Data (PCPD). This document should be implemented by any organization that collects, processes, or stores personal data of clients in Hong Kong. The policy must clearly communicate the organization's data handling practices, ensuring transparency and compliance with Hong Kong's data protection principles. It includes mandatory disclosures about data collection purposes, retention periods, security measures, and data subject rights, while addressing specific Hong Kong requirements such as direct marketing consent and cross-border data transfers. Regular reviews and updates are necessary to maintain compliance with evolving privacy regulations and business practices.
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1. Introduction: Overview of the policy and its purpose
2. Scope and Application: Who the policy applies to and what activities it covers
3. Definitions: Key terms used throughout the policy, including 'personal data' as defined under PDPO
4. Types of Personal Data Collected: Comprehensive list of personal data categories collected
5. Purpose of Collection: Specific purposes for which personal data is collected and used
6. Data Collection Methods: How personal data is collected (direct collection, cookies, etc.)
7. Use of Personal Data: How collected personal data is used by the organization
8. Disclosure and Transfer of Personal Data: Circumstances under which personal data may be shared with third parties
9. Data Retention: How long personal data is kept and retention criteria
10. Data Security: Measures taken to protect personal data
11. Your Rights: Data subject rights under PDPO including access and correction
12. Contact Information: How to contact the organization regarding privacy matters
13. Updates to Privacy Policy: How changes to the policy will be communicated
1. Direct Marketing: Required if personal data is used for direct marketing, detailing consent requirements and opt-out procedures
2. Cross-border Transfers: Required if personal data is transferred outside Hong Kong
3. Automated Decision Making: Required if using automated processing or profiling
4. Children's Privacy: Required if services may be used by or data collected from children
5. Cookie Policy: Required if website uses cookies or similar tracking technologies
6. Social Media Integration: Required if services integrate with social media platforms
7. Employee Data Processing: Required if policy covers employee personal data
8. CCTV and Surveillance: Required if premises use surveillance systems
1. Cookie List: Detailed list of cookies used, their purposes and duration
2. Third Party Processors: List of data processors and their roles
3. Data Retention Schedule: Detailed retention periods for different types of personal data
4. International Transfer Mechanisms: Details of safeguards for international data transfers
5. Privacy Impact Assessment Summary: Summary of privacy impact assessments for high-risk processing
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