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Legal Update

Guess Who’s Looking at Your Ad? Blind Recruitment Ads Fall Foul of Data Privacy Laws

26 June 2014
Mayer Brown Legal Update

The number of "blind" recruitment ads – i.e., ads that do not identify the employer or their recruitment agent – circulating in Hong Kong has led to a growing concern about the possible unscrupulous collection and use of personal data of job applicants. In response:

  • The Privacy Commissioner initiated a number of investigations in relation to the use of blind recruitment ads.
  • Blind recruitment ads are deemed to be in breach of the Hong Kong Personal (Data) Privacy Ordinance ("PDPO") because they are an unfair means of collecting personal data.
  • The Privacy Commissioner has issued a report on the results of its investigations regarding the use of blind recruitment ads, and also a new information leaflet to provide further guidance on the use of recruitment ads.

Companies are advised to review their recruitment practices to ensure that they do not breach the PDPO, and that they have proper privacy management procedures in place. A useful starting place is to consider the issues highlighted in the Privacy Commissioner's report and the guidance provided by the information leaflet, as discussed in this legal update.


  • Gabriela Kennedy
    T +852 2843 2380
  • Hong Tran
    T +852 2843 4233
  • Karen H. F. Lee
    T +852 2843 4452
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