Date:19 February 2021
“LeaveHomeSafe” Mobile App
in Compliance with the Requirements of the Privacy Law
The Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD), noted that some members of the public are concerned about the protection of personal data privacy relating to the use of the “LeaveHomeSafe” mobile app (“LeaveHomeSafe”). The PCPD would like to make the following explanation:
The PCPD understands that “LeaveHomeSafe” does not have a location tracking function. Neither does it collect users’ Global Positioning System (GPS) data. Therefore “LeaveHomeSafe” does not have the function of tracking users’ movements.
The downloading of “LeaveHomeSafe”, which can be used immediately after download, does not involve registration of the users’ personal data. No collection of any personal data is involved during the process of download.
Visit records are kept on users’ mobile phones only, not in any Government systems. There is no transfer of personal data to the Government’s system or operators of premises for retention.
Visit records will be automatically erased after 31 days.
Only in the unfortunate event of a confirmed infection as ascertained by the Centre for Health Protection (CHP) will the infected person be required under the Prevention and Control of Disease (Disclosure of Information) Regulation (Cap. 599D) to upload the relevant visit records and provide his/her name and contact telephone number to assist the CHP in contact tracing.
Overall, the PCPD considers “LeaveHomeSafe” to be in compliance with the relevant requirements of Personal Data (Privacy) Ordinance. In terms of data storage, “LeaveHomeSafe” adopts the “decentralised” storage model (i.e. storage in users’ mobile phones only) used by contact tracing mobile apps across the world. There is no “centralised” storage system.
If members of the public have any questions about the protection of personal data privacy relating to “LeaveHomeSafe”, they may contact the PCPD (phone: 2827 2827 or email: firstname.lastname@example.org) for enquiries.