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Case Notes

Case Notes

This case related to DPP1 - Purpose and manner of collection of personal data

Case No.:2021C03

A hospital collected the time spent by a doctor on wards rounds and the number of patients he attended to, without prior notification – DPP 1 – collection of personal data

The Complaint

The complainant was a doctor at a public hospital. He was dissatisfied that the hospital management collected statistical data concerning him, such as the time he spent on ward rounds and the number of patients he attended to, without any prior notification.


The hospital management explained that, due to changes in clinical service model, it collected data including doctors' consultation time and number of patients attended to for calculating the service cost for different types of patients.

After the PCPD's intervention, the organisation managing the hospital promised to amend its internal guidelines to ensure that they covered the situations in which the employees' personal data were collected, and clearly stated the purpose and use of such collection. Moreover, the organisation sent emails to its employees, reminding them to inform colleagues of the purpose of collection before collecting the personal data from them.

Regarding the incident, the PCPD issued a warning to the organisation, requesting it to closely monitor its employees' compliance with the said guidelines.

Lesson learnt

The hospital management collected data for administrative and statistical purposes, which were directly related to its function of managing the hospital. However, the management collected the data without informing the doctors of the collection purposes. Hence, when the doctors learnt that the management had collected such data without prior notification, inevitably they speculated or were worried that the data was used to evaluate their work performance. Trust was hence damaged. The PCPD was pleased that the organisation had promptly taken the above remedial actions, and improved the transparency of personal data collection to avoid suspicion and rebuild trust with its employees.

(Uploaded in March 2022)

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