Q: We are staff members of a government department. The department has recently instituted new procedures requiring staff members seeking re-engagement after early retirement or contract renewal to make fresh detailed financial declarations. Do the new arrangements contravene the Personal Data (Privacy) Ordinance ("the Ordinance")?
A: Given the work nature of the staff members concerned, it appears to us that it is reasonably necessary to require a declaration of financial interests from any prospective new member. We understand that the personal data collected are to be used for the purpose of assessing the suitability of applicants seeking employment/re-employment or further employment. As the data are collected for a lawful purpose directly related to the function or activity of the department concerned and the collection of the data is necessary for that purpose, it seems unlikely that such collection would contravene Data Protection Principle 1(1)(a) or (1) (b) of the Ordinance.