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Client Privacy Policy Template for Hong Kong

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Key Requirements PROMPT example:

Client Privacy Policy

"I need a Client Privacy Policy for my Hong Kong-based e-commerce platform that will launch in March 2025, with specific sections on cross-border data transfers to mainland China and cookie tracking for personalized shopping experiences."

Document background
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.
Suggested Sections

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

Optional Sections

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

Suggested Schedules

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

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈ˰æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions






























Clauses





























Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Education

Professional Services

Retail

Insurance

Telecommunications

Real Estate

Manufacturing

Hospitality

Transportation

Media and Entertainment

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Marketing

Customer Service

Operations

Human Resources

Data Protection

Privacy

Digital

Technology

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Legal Officer

Compliance Manager

Privacy Manager

Legal Counsel

IT Security Manager

Risk Manager

Chief Information Security Officer

Customer Relations Manager

Operations Director

Chief Technology Officer

Marketing Director

Human Resources Director

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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