4 : Check that you use ID card numbers only for one or other
of the purposes permitted by the code
Where a data user has collected
an ID card number for a purpose allowed under the code, the
ID card number should generally be used only for that purpose.
In addition, the code allows ID card number to be used for
the following further purposes.
- To manage records relating to the individual that are
held by the data user e.g. a bank may use the ID card number
as a key to link the records relating to a particular customer.
- To manage records relating to the individual that were
collected for the same particular purpose but which are
held by more than one data user e.g. the ID card number
could be used to manage an individual's records under the
proposed mandatory provident fund scheme, which will be
held by more than one data user.
- To carry out a "matching procedure" that is permitted
under the Ordinance. Note: For guidance on what constitutes
a "matching procedure" under the Ordinance and the circumstances
under which such procedures are permitted, see the PCPD's
leaflet "Matching Procedure: Some Common Questions".
- For a purpose that is required or permitted under any
other code of practice that has been approved and is in
force under the Ordinance.
- For a purpose to which the individual has voluntarily
given his or her express consent.
- For a purpose permitted by an applicable exemption in
Step 5 : Check that you are
NOT publicly displaying or disclosing ID card numbers with
the names of the ID card holders and that you are NOT issuing
cards such as staff cards with ID card numbers printed on
Unless required or permitted by
law, a data user should not:
display together an individual's name and ID card number, e.g. in a newspaper
notice announcing the results of a raffle, or
- make an individual's name and ID card number visible together
to anyone who does not need to carry out activities related
to the permitted uses of the ID card number, e.g. entries
in a visitor's log book that include names and ID card numbers
should be concealed from subsequent visitors who enter their
Furthermore with effect from 19 December 1998, a data user
should not issue a card to an individual that has the individual's
ID card number printed on it in a legible form, e.g.
a staff card with the holder's ID card number printed on
it in a form that is capable of being read directly by other
prohibition applies whether or not the card is worn as a badge or is only
used while the individual is in particular premises, e.g. the offices of the
issuing party. The ID card itself and the driving licence are excluded from
Step 6 : Check that you do not
keep records of ID card numbers for longer than is necessary
to fulfill the purpose for which they were collected
Specifically, the code contains
the following requirements.
- Where an ID card number is collected for future identification
of an individual who has been permitted to enter premises
or use equipment, the record should be erased within a reasonable
period after the individual has left the premises or ceased
to use the equipment.
- Where an ID card number is collected as a condition for
giving the individual custody or control of property, the
record should be erased within a reasonable period after
that custody or control has ceased.
Note: A reasonable period in the above contexts would
be days rather than weeks
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