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Case Notes

Case Notes

This case related to DPP4 - Security of personal data

Case No.:2024C02

Mobile Wi-Fi device rental company took inadequate security measures to protect customers’ personal data

The Complaint

The complainant was a customer of a mobile Wi-Fi device rental company (“the Company”). While picking up a Wi-fi device at the Company’s counter located at the Hong Kong International Airport (“the Counter”), the complainant noticed that the acknowledgment of receipt form (“the Form”) used allowed him to access personal data of other customers, including their full English names, rental periods and destinations. On the other hand, the Company left the Form unattended at the Counter during non-business hours and the customers were requried to acknowledge receipt of the Wi-fi devices on their own. This situation might lead to unauthorised access to customers’ personal data.


After PCPD’s intervention, the Company revised the format of the Form, namely, remove the “destination” column and display only the customer’s family name with the initial of the given name so that the identity of the customer could not be ascertained from the limited information available on the Form. On the other hand, the Company had covered the Form with non-transparent sheets to avoid accidental access to customers’ personal data on the Form.

Besides, the PCPD issued an advisory letter to the Company in response to the incident requesting it to take all practicable measures to protect the registration data of customers against unauthorized or accidental access, processing, erasure, loss or use. Meanwhile, the Company is requested to provide training to staff to raise their awareness of personal data privacy protection.

Lesson learnt

The use of common forms by data users to record personal data is not uncommon. However, this practice is not advisable as it may lead to customers accessing the data of customer who had registered earlier on, resulting in leakage of customers’ personal data. Considering the business operation model in the present case, the PCPD understands that it may be impracticable for the Company to arrange staff to be available around the clock to complete the pick-up procedures. To minimize the risk of personal data leakage, data users should focus on the format of the acknowledgment form by displaying only the necessary information for the purpose of acknowledging receipt. Meanwhile, data users may consider digitizing such process by using a computer system instead of physical common forms. As such, customers would not have access to other customers’ personal data when completing the acknowledgment procedures, thereby ensuring better protection of customers’ personal data privacy.

(Uploaded in February 2024)

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