Q: We are a government department and are organizing a scheme of outstanding achievements awards to commend and promote outstanding practices in certain public service providers. Under the scheme, the relevant service providers are assessed by a panel of adjudicators. The adjudicators are mostly volunteers drawn from the relevant service sector. They provide written comments on each of nominations assessed by them. The comments are on the performance of the nominated service providers rather than on any individuals. The question is whether the release of such comments to the general public is covered by the Personal Data (Privacy) Ordinance ("the Ordinance").
A: The purpose of the Ordinance is to promote and protect the privacy of individuals in relation to personal data. So long as the comments on the performance of the nominated service providers do not contain the identity or other identifying particulars of a living individual, it will fall outside the definition of "personal data" as defined by the Ordinance and is not subject to the requirements of the Ordinance.