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In Brief

Revised Code of Practice on Human Resource Management and Guidelines on Monitoring at Work Issued

6 May 2016
Mayer Brown In Brief

Hong Kong's Privacy Commissioner has issued a revised Code of Practice on Human Resource Management (the "Code") and a revised Privacy Guidelines for Monitoring and Personal Data Privacy at Work (the "Guidelines").

Neither the new Code nor the new Guidelines include any material change from their existing versions. The only changes are the new Code updates certain references to amendments in the Personal Data (Privacy) Ordinance (PDPO) and removes one provision of the Code that has become obsolete (namely the transitional provision exemption in relation to compliance with data access requests that expired in 2002).

As a reminder, the Code is designed to give practical guidance to data users who handle personal data in performing human resource management functions and activities. Where a data user fails to comply with the Code, a court, magistrate or Administrative Appeals Board may take that fact into account in deciding whether there has been a breach of the PDPO.

The Guidelines provide guidance on the application of the PDPO to employee monitoring and set out best practices for managing personal data obtained from such activity.

The revised Code and Guidelines are available at the following links:


  • Duncan A. W. Abate
    T +852 2843 2203
  • Hong Tran
    T +852 2843 4233
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