Table of Contents

You may use this document to discharge your legal obligations under Personal Data (Privacy) Ordinance (Cap 486) to inform an employee how his/her personal data will be used, why you collect them and the consequences if certain data is not provided. Your PERSONAL INFORMATION COLLECTION STATEMENT (PICS) may be for a general or specific purpose. This PICS is for the specific purpose of employment. The scope of this statement covers the whole course of your employee’s employment, from commencement to termination. The document you are about to build will be consistent with your DATA PROTECTION POLICY. You may want to consult your Data Protection Policy when building this document.

We strongly recommend you build a PICS for employment if you are about to hire unless you have other measures in force that serve the same purpose. This document is required for compliance with Hong Kong law. Make sure you provide every employee with a copy of this PICS.

If you intend to build a PICS covering the information that a job seeker provides, you should instead select a PERSONAL INFORMATION COLLECTION STATEMENT (RECRUITMENT) because the information to be collected for a job seeker is materially different and so are the parties with whom you will share such information.

Is an email address considered personal information?

As per data protection laws such as GDPR and CCPA, email addresses are personally identifiable information (PII) and so they are personal data. Any information that can be used on its own to identify a physical person is known as a PII.

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About Author

Daniel Walker

Daniel Walker

Daniel Walker is the Founder and Chief Executive Officer of Zegal, the trusted legaltech firm. Prior to founding Zegal, Daniel practised at DLA Piper, Stephenson Harwood and Clyde & Co, in Hong Kong, Singapore, and the UK.

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