APLUZA Academy, as a Data User, respects the privacy of personal data. The Academy is fully supportive of and committed to upholding the spirit of the six Data Protection Principles and to complying with the requirements of the Ordinance in its management practices. For compliance with the requirements of the Ordinance, the Academy has prepared the “Code of Practice for compliance with the Data Protection Principles specified in The Personal Data (Privacy) Ordinance” to ensure compliance by staff members in the strictest standards of security and confidentiality.
Purpose and manner of collection of personal data
- Personal data will only be collected for a lawful purpose, and by lawful and fair means. Data collected concerning a specified purpose must be adequate but not excessive in respect of the purpose. The Data Subject must be informed explicitly on collection:
- purpose(s) for which the data are to be collected and the groups of persons to whom the data may be transferred;
- whether it is obligatory or voluntary for such data to be supplied, and the consequences of not supplying the obligatory data;
- the right of the Data Subject to request access to, and correction of data held by the Data Users; and
- the person in charge to handle such data access and correction requests.
Accuracy and duration of retention of personal data
- All reasonably practicable steps will be taken to ensure that the personal data kept is accurate.
- Personal data will not be kept longer than is necessary for the fulfillment of the purpose for which it is collected.
Use of personal data
- Without the prescribed consent of a Data Subject, the personal data will not be used for any purpose other than the purpose for which the data was originally collected. The prescribed consent may be withdrawn by a Data Subject.
Security of personal data
- All reasonably practicable steps will be taken to ensure that personal data held are protected against unauthorized or accidental access, processing, erasure, or other use.
- Regarding the transmission of personal data over the Internet, the Academy has imposed the following security measures:
- Encryption – The Academy is continuously enhancing the implementation of encryption mechanisms in protecting the Academy’s data. Encryption technology, such as SSL, will be employed whenever possible, for the transmission of data collected online. The Academy servers are, to the maximum possible extent, protected against security attacks over the Internet employing system securities set up and the “Firewalls”. A well-organized and safe system of backups is in place.
- As such, users’ data supplied to the Academy will reside in the Academy’s servers which are protected to the maximum possible extent against unauthorized or accidental access, processing, erasure, or other illegitimate manipulation.
- Any information collected by “cookies” is anonymous and does not contain any personal data. Although through cookies, the Academy’s web servers can monitor which sites the users have visited, which pages they have seen and which options they have chosen, the Academy will NOT make any analysis on these cookies data NOR provide such data to outside organizations.
- At the same time, the Academy does not allow users, both internal and external, to make rude and or annoying spamming which includes sending unsolicited emails, making mailbombs, disseminating commercial advertisements/promotions, and distributing mail chains letter. Appropriate action including legal prosecution may be taken to the offenders.
Information to be generally available
- The following information concerning personal data of the Academy will be generally available:
- the kinds of personal data held;
- the main purpose for which personal data are used; and
- the policies and practices concerning personal data.
Access to personal data
- A Data Subject will have the right to request access to his/ her data held by a Data User, through writing to the data holding department/office. A fee, which is not excessive, will be charged for the processing. The Data Subject will be notified of the outcome within 40 days of submitting his/her access request, and to be given a reason if a data correction request is refused.
- A Data Subject also has the right to request the data holding department/office in writing the correction of his/her data.
Management personal data
- For each group of data collected from a Data Subject or a group of Data Subjects, the Academy designates the department/office which collects, holds, and uses the data as the Primary (Data) Holder (PH). It is held responsible for updating, protecting, providing access to, and meeting requests for access/correction from the Data Subjects. The other departments/offices which make use of the same data transferred from the PH are the Secondary Data Users (SDUs). SDUs are expected to observe the six Data Protection Principles as well, particularly concerning the duration of data retention and use and security of data.
- Data Users should adhere to the Data Protection Principles and draw up internal guidelines and practices for adoption by members of their respective departments/ offices where appropriate.
- A Data Protection Officer is to be appointed from each Faculty/School/Office of the Academy to help protect the privacy of the data held in the Faculty/School/Office, in compliance with the six Data Protection Principles, review and improve the relevant internal process and enhance the awareness of protecting personal data privacy among his or her colleagues in the Faculty/School/Office.
- The kinds of personal data held by the Academy and the respective purpose(s) of the collection are enclosed for information.
- Personal data held by the Academy and the respective purpose(s) of collection
- Personal data kept in different Faculties/Schools/Offices vary depending on their purpose of collection. In general terms, personal data could be classified as factual, evaluative, or statistical data. Factual data are mostly provided by the Data Subjects themselves, evaluative data are normally provided by another person on the Data Subjects, whereas statistical data are derived primarily from factual and evaluative data. For the latter purpose, personal data are depersonalized before statistical analyses are performed. Examples of personal data kept by the Academy include the following:
- identification data, e.g., name, Identity Card/Passport No., photo, etc.
- personal details, e.g., age, sex, date of birth, contact telephone, address, etc.
- family data, e.g., marital status, details of other family members, etc.
- contractual data, e.g., appointment period, terms of appointment, etc.
- education background and employment details
- record of assessment and review, e.g., self-statements, review/promotion panel resolutions, etc.
- Personal data of Job Applicants kept in the Personnel Office include applicants’ particulars, copies of qualifications, a record of experience, test results, interview assessment, resolution of the assessment panel, last employers’ references, external assessors’ reports, etc. They are kept for recruitment administration purposes. These personal data will be transferred to the relevant Faculty/School/ Department/Office for recruitment consideration and will be kept until the completion of the recruitment exercise.
- Personal data of Staff of the Academy are kept for various purposes in manpower planning and management, development and maintenance of employment relationship. These will include the provision of access to and usage of Academy facilities, benefits, remuneration, and payroll, preparing tax returns, facilitating performance appraisals, review of appointment, promotion, granting awards/fellowship, organizing training and development activities. Staff data may be transferred to the Departments/Offices of the Academy providing facilities or staff benefits, insurers, medical and dental practices/consultants, fund administrators/ managers of the Superannuation Fund or Mandatory Provident Fund Scheme(s), and auditors appointed by the Academy for the above-mentioned purposes.
- Personal data of Former Staff of the Academy are kept in the Personnel Office. Physical personal files of former staff, which contain personal particulars, family data, contractual data, evaluative data, and other benefits-related data, will be destroyed after a retention period. Basic data of former staff will be kept electronically for the provision of the certificate of service.
- Personal particulars, examination results, and evaluative data of Student Applicants are collected as a basis for the selection of applicants for admission. Data of successful applicants will be transferred and become part of the student records kept by the Academy. These data in electronic format with personal identification data masked will be kept for statistical purposes. All hard copies of unsuccessful applications will be destroyed upon completion of the admission process.
- Personal data of Students of the Academy, including personal particulars, family data, education background, academic and assessment records, as well as senate resolutions, are kept for registration, academic and administrative communication, statistical purposes as well as provision of student welfare services. Upon graduation of students, their data and basic study information will be transferred to the Alumni Affairs Office of the Academy and become Alumni data.
- Personal data of Alumni, Donors, and Prospective Donors are collected, kept, and used for handling donation-related matters, sending news and updates, the invitation to the Academy, events and gatherings, data analyses, and generation of statistical reports.
- Should you have any queries concerning the Policy please call +852 5112 3879