Context

• The law is a mess

• Need for greater clarity and certainty

• Legislative changes ?

• Privacy Ordinance ?

  • Clarify application of the Data Protection Principles

• Code of Practice can provide clarity and guidance

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Very uncertain legal position

May conclude need for specific legislative changes

Privacy Ordinance imposes some parameters, but implications of DPPs need to be spelt out

Privacy Code an serve two purposes

• clarify law, including DPPs, and

• offer best practice guidance

(must distinguish)