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Case Notes

Case Notes

This case related to DPP1 - Purpose and manner of collection of personal data

Case No.:2011C13

Excessive collection of locker users’ Hong Kong Identity Card numbers for security purposes by a public sports centre

The Complaint

In response to the Complainant’s request for use of a locker in a public sports centre, the serving staff asked for his Hong Kong Identity Card number (“ID card number”). The Complainant questioned the necessity of collecting his ID card number, as he had already provided his name and telephone number when registering for use of the locker.

The sports centre explained to the Commissioner that the collection of ID card numbers from locker users enhanced the management and security of the sport facility. However, the sports centre was unable to provide any information about suspected crimes committed by locker users.

Outcome

The Commissioner was of the view that the sports centre could not collect locker users’ ID card numbers solely because of potential risk of crime committed by them. If locker users reported the loss of their locker keys, the most effective way to identify the locker users was to ask them to give the names and telephone numbers they provided upon registration for verification. If the sports centre still doubted their identity, it could also ask them to produce an identification document bearing their photos for verification.

The Commissioner concluded that the sports centre’s collection of ID card numbers of locker users had contravened DPP1(1). An enforcement notice was served on the sports centre directing it to cease the practice and destroy all records of ID card numbers so collected. The sports centre complied with the enforcement notice.

uploaded on web in January 2014


Category : Provisions/DPPs/COPs/Guidelines : Topic/Subject Matter :