The Ordinance

Your Identity Card Number and Your Privacy - A Guide to Individuals

SITUATION 8:
ASKING YOU TO TRANSMIT YOUR ID CARD COPY

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When you send a copy of your ID card by post, put the ID card copy in an envelope marked "confidential"

Under the Code, organisations are required to treat ID card copies as confidential documents. If they request that an ID card copy be transmitted to them, e.g. by post or fax, they are also required to take all reasonably practicable steps to ensure that the copy will be received only by the intended recipient and be kept in a secure manner.

[image]Action you can take: When you send a copy of your ID card to an organisation by post, put the copy in a sealed envelope marked "Confidential" for the attention of the individual or the organisational unit that is responsible for the matter concerned.

Action you can take: If you are asked to send a copy of your ID card by fax or other electronic means, you may consider asking about the measures taken to ensure the security of the copy once it has been transmitted. Possible safeguards include fax "padlocks", "confidential mail boxes", password control and having a dedicated fax in a secure area for receiving confidential documents.

An organisation may be contravening the Code if it is unable to give you a reasonable answer about its security measures.

SITUATION 9:
DISPLAYING YOUR NAME WITH YOUR ID CARD NUMBER

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Organisations should not publicly display your name together with your ID card no.

Organisations should not publicly display your name together with your ID card no. Unless otherwise required or permitted by law, organisations should ensure that an ID card number and the name of the holder are not displayed together publicly. They should also ensure they are not made visible or otherwise accessible together except to persons who need to carry out activities related to permitted uses of the ID card number.

One common situation in which a breach of the above requirement may occur is the publication of notices including individuals' names and ID card numbers in a newspaper, e.g. notices carrying the result of a lucky draw or a competition. Another is the display of notices containing individuals' names and ID card numbers on a notice board in places such as a school, an office, or the lobby of a residential building. A further one is the inadvertent disclosure of the names and ID card numbers of visitors' to subsequent visitors to a building in a visitors' log-book.

Action you can take: Where you encounter a situation such as those described above, ask the organisation to stop or else to justify the display or disclosure.

An organisation may be contravening the Code if it cannot provide a good justification.

SITUATION 10:
ISSUING YOU A CARD BEARING YOUR ID CARD NUMBER

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Organisations should not issue to you a card bearing your ID card no.

Under the Code, an organisation should not issue to an individual a card (not being the Hong Kong ID card or driving licence) bearing in a legible form the ID card number of that individual.

This prohibition applies even if the card bears an altered form of the ID card number from which the ID card number may be deduced. It also applies even if the card issued is not required to be worn or publicly shown. This particular requirement of the Code takes effect on 19 December 1998, which is 6 months later than the other requirements.

All staff, student, medical and other cards issued by organisations such as employers, schools, universities and insurance companies are subject to this requirement.

Action you can take: If an organisation has issued, or proposes to issue, a card to you bearing your ID card number, point out to the issuing body that this is contrary to the Code.

ENQUIRIES AND COMPLAINTS

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If you have any questions, you are welcome to approach the PCPD for guidance.

If you think an organisation's practices in relation to ID card numbers or copies do not comply with the requirements of the Code, you should, in the first instance, query this with the organisation concerned in the manner suggested above. If you do not get a reasonable answer, you can approach the Office of the Privacy Commissioner for Personal Data (PCPD) for further guidance on the issue or to make a complaint, as appropriate. The PCPD hotline is 2827 2827.

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