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Case Notes

Case Notes

This case related to ID number/ ID copy

Case No.:2015C01

Excessive collection of copies of Hong Kong Identity Card (“HKID Card”) of parents by a kindergarten - DPP1(1)

The Complaint

The Complainant applied for admission to a kindergarten for her son. Apart from the application form, the Complainant was requested to provide a copy of her HKID Card. The Complainant queried the purpose of the kindergarten to collect a copy of her HKID Card.

The kindergarten explained to the Commissioner that a copy of the Complainant’s HKID Card was needed for verifying the relationship between the applicant (the student) and the Complainant who submitted the application. The copy of the Complainant’s HKID Card also facilitated the kindergarten to issue the “student pick-up card” for the parent/ guardian designated to pick up the student from school.


Given that HKID Card number was a sensitive personal data, data user should not collect a copy of HKID Card lightly without genuine need or justification.

For the purpose of simply verifying the relationship between the applicant and his parent/ guardian, the kindergarten could ask the parent/ guardian to present his HKID Card when submitting the application in person or when attending the school interview. The kindergarten could then verify the name on the HKID Card against the names of the parents recorded on the birth certificate of the applicant or any other relevant legal document. Based on the verification result, the kindergarten might issue the “student pick-up card” accordingly. If the kindergarten doubted the identity of the person who came to pick up a student, it might ask that person to present his HKID Card and verify his name against the record.

The Commissioner was of the view that the collection of copies of HKID Card of the parents/ guardians was excessive and in breach of DPP1(1).

As a result, the kindergarten agreed to stop collecting copies of HKID card of the parents/ guardians, and to destroy all copies of HKID Card previously collected.

(Uploaded in September 2016)

Category : Provisions/DPPs/COPs/Guidelines : Topic/Subject Matter :