PCPD - A Guide for Data Users -- No. 3 -- Outline Action Plan for Complying with the Data Protection Principles

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Personal Data (Privacy) Ordinance
A Guide For Data Users No. 3
Outline Action Plan For Complying with the Data Protection Principles

ACTION 3 - Ensure Accuracy

Data Protection Principle 2 - accuracy and duration of retention of personal data

Review whether your arrangements for checking and updating personal data meet the requirement to take all reasonably practicable steps to ensure accuracy having regard to the purposes for which the personal data are used. For personal data to be accurate, all statements of purported fact contained in the data should be correct. The accuracy requirement is not directly concerned with statements of pure opinion, although all reasonably practicable steps should be taken to ensure that any facts cited in support of such an opinion are correct.
Where a purpose requires the holding of historical personal data, accuracy is a matter of whether the data correctly reflect the position at the time to which they refer. For example, a purpose may require the holding of data about a person's past income. In such a case, a correct statement of that person's income at a particular time in the past that is recorded by reference to that time would meet the accuracy requirement.
Review whether you have reasonable grounds for believing that personal data held by you are inaccurate having regard to the purposes for which they are used. If you have doubts about the accuracy of personal data you hold, you must either correct or delete the data concerned.
If you disclose or transfer personal data to third parties, ensure that you have arrangements for forwarding corrections to the parties concerned.
Review whether your arrangements for disposing of obsolete records meet the requirement that personal data shall not be kept for longer than is necessary for the purposes for which they are used. Consider, if you have not already done so, the adoption of standard review and retention periods for different types of personal data. If you need to keep personal data for statistical purposes, consider whether such purposes can still be achieved if the data are made anonymous by removing information that makes it possible to identify the subject of the data.

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