The Ordinance

Application of the Personal Data (Privacy) Ordinance Code of Practice on Human Resource Management Frequently Asked Questions About Recruitment Advertisements

Common questions

Q1:
What is a "blind" recruitment advertisement in the context of the Code?
A: Generally speaking, a "blind" recruitment advertisement is one that does not identify either the employer or the employment agency acting on its behalf.

Q2:
Does the Code apply to all recruitment advertisements?
A: No. The Code only applies to recruitment advertisements that directly solicit personal data from job applicants. Under the Code, an employer or the employment agency acting on its behalf is not permitted to place a "blind" recruitment advertisement that directly invites job applicants to submit their resumes or CVs. Where there are no direct solicitation of personal data in a recruitment advertisement, such an advertisement would not be subject to the requirements of the Code. For example, if the advertisement merely invites job seekers to write in to obtain an application form or contact a representative person, there is no direct solicitation of personal data.

Q3:
Under what circumstances can job applicants be asked in a recruitment advertisement to submit personal data?
A:
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An employer or recruitment agency who clearly indicates its identity may ask job applicants to submit personal data in a recruitment advertisement, provided that the data are adequate but not excessive in relation to the purpose of recruitment and are to be used lawfully (section 2 of the Code).
  Example of Q3
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