Licences and Permits with inclusion of ID number.
Q: Is it a contravention of the Ordinance
to have licences and permits displaying ID card numbers which
would likely be displayed in a conspicuous place?
A: Unless this is required or permitted
by law, this practice is contrary to the requirements of paragraph
2.7 of the Code of Practice on the ID Card Number and other Personal
Identifiers approved and issued by the Privacy Commissioner for
Personal Data on 19 December 1997 ("the Code"). To ascertain whether
the said practice is required or permitted by law, I suggest you
seek advice from your legal advisers. Even if the practice is,
it does not appear to us to be necessary to display the ID card
number of the licensee or permittee. This is because an authorised
inspector from the relevant department could check the ID card
number of the licensee or permittee in a separate record, to which
access is restricted as specified in paragraph 2.7.2 of the Code,
by reference to the licence or permit number. Accordingly, even
if the current practice does not contravene paragraph 2.7 of the
Code, as a matter of good practice it is suggested that action
is necessary to remove the ID card number field from the relevant
permits and licences.
