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Standard Privacy Notice Template for Hong Kong

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Standard Privacy Notice

I need a Standard Privacy Notice for my Hong Kong-based fintech startup that processes customer payment data and transfers data to cloud servers in Singapore, with planned implementation by March 2025.

What is a Standard Privacy Notice?

The Standard Privacy Notice is a fundamental document required for compliance with Hong Kong's Personal Data (Privacy) Ordinance (PDPO). Organizations operating in Hong Kong must provide this notice to data subjects at or before the time of data collection, explaining how personal data will be handled. The document should be used whenever an organization collects, processes, or stores personal data of individuals in Hong Kong. The Standard Privacy Notice typically includes information about data collection purposes, retention periods, security measures, third-party sharing, and data subject rights. It must be written in clear, understandable language and should be regularly reviewed and updated to reflect changes in data processing practices or regulatory requirements. For organizations dealing with mainland China or international operations, the notice may need to be aligned with other privacy regulations while maintaining PDPO compliance.

What sections should be included in a Standard Privacy Notice?

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

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

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

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

6. Data Security: Measures taken to protect personal data

7. Data Subject Rights: Rights of individuals under PDPO including access and correction rights

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

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

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

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

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

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

5. Third-Party Processing: Required if third-party processors handle the personal data

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

What schedules should be included in a Standard Privacy Notice?

1. Schedule 1: Categories of Personal Data: Detailed breakdown of all personal data categories collected and processed

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

3. Schedule 3: Technical and Security Measures: Detailed description of security measures implemented to protect personal data

Authors

Alex Denne

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

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Relevant Industries

Technology

Financial Services

Healthcare

Retail

E-commerce

Education

Professional Services

Insurance

Telecommunications

Manufacturing

Real Estate

Hospitality

Transportation

Media and Entertainment

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Data Protection

Privacy Office

Corporate Governance

Customer Relations

Human Resources

Relevant Roles

Data Protection Officer

Chief Privacy Officer

Chief Compliance Officer

Legal Counsel

Privacy Manager

Compliance Manager

Information Security Officer

Risk Manager

Chief Technology Officer

Chief Information Officer

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, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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