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1. Policy statement
1.1 Everyone 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.
1.2 Data 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
2.1 The types of personal data that Okay Healthcare 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”).
2.2 This 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.
2.3 It sets out rules on data protection and the legal conditions that will be satisfied when we obtain, handle, process, transfer and store personal data.
2.4 The 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
3.1 Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
3.2 Data 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.
3.3 Personal 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.
3.4 Data 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.
3.5 Data 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.
3.6 Data 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.
3.7 Processing 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:
5. Fair and lawful processing
5.1 The 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.
5.2 For 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
6.1 In 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).
6.2 We 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
7.1 If we collect personal data directly from data subjects, we will inform them about:
7.2 If 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.
7.3 We 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.
9. Accurate data
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.
10. Timely processing
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:
12. Data security
12.1 We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
12.2 We 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.
12.3 We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
12.4 Security procedures include:
13. Transferring personal data to a country outside HKSAR
13.1 We may transfer any personal data we hold to a country outside HKSAR, provided that one of the following conditions applies:
13.2 Subject 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
14.1 We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
14.2 We may also disclose personal data we hold to third parties:
14.3 If 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
Okay Healthcare 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.