Personal Information Collection Statement (PICS)
This statement (“PICS”) provides you, as the data subject to whom the data user, Common Care Limited (“CCL”), provide services, with notice as to why your personal data (“Data”) is collected, how it is intended to be used, to whom the Data may be provided to, and how to access, review and correct the Data, in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”).
It is important that you read this PICS, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Why we collect your personal data and how it may be used?
A. We shall collect from you:-
your personal particulars such as your name for the purpose of identification; and
your email address for the purpose of communicating with you; and
your age
The provision of this data is obligatory. If you are not willing to supply such data, CCL will be unable to accept you for diagnostic or treatment purposes.
B. We shall also collect information regarding your medical history or condition, preferences in therapists, type of therapy, preferred availability, budget, screening for suicidal ideation including self-harm and harm to others:-
by asking you for such data; and
by means of normal clinical diagnostic procedures.
Please note that it is mandatory for you to provide personal data marked with asterisks as listed in the Common Care Online Therapy Client Intake Questionnaire. (i.e. information required for creating an account, and to enable you to access the features of the website and receive the Service.) This type of personal data is for the purpose of assessing your suitability for acceptance for therapy. The provision of such personal data is also obligatory, otherwise CCL cannot accept you for diagnostic or treatment purposes.
When you provide such personal data to us, please make sure that the data is accurate and complete. If you do not provide us with the information required or if the information provided is inaccurate or incomplete, our ability to provide accurate diagnosis or appropriate treatment to you may be affected.
C. We shall also collect from you information about your age, gender, religion and concerns for [recommendation of suitable therapy providers and services to you]. Provision of these types of personal data is voluntary and you may decline to provide such information if you so wish.
Who may be provided with your personal data?
The Data will be kept confidential but may, where such disclosure is necessary to satisfy the purpose or a directly related purpose for which the Data was collected, provide the Data to the following parties:-
Internal Parties: CCL’s staff who provides services such as risk management, HR, IT and system administration services and undertake leadership reporting;
External Parties: service providers acting as processors who provide services to CCL and employees such as IT and system administration services and company registrations or agencies. Professional advisers acting as processors who provide services to CCL and employees. Regulators and other authorities acting as data processors who require reporting of processing activities in certain circumstances.
Use and Provision of Personal Data in Direct Marketing: we may use your personal data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose.
In addition to the purposes set out above, where permitted by law, CCL may use your name and contact details for promotional or marketing purposes including sending you promotional materials and conducting direct marketing in relation to the Service ("Classes of Marketing Subjects").
For the purposes of direct marketing, we may, where permitted by law, provide your personal information to providers whether within or outside of CCL of any of the Classes of Marketing Subjects described above and call centre, marketing or research services so that they can send you promotional materials and conduct direct marketing in relation to the products and services they offer (these materials may be sent to you by postal mail, email or other means).
Before using or providing your personal data for the purposes and to the transferees set out in this section, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use and provide your personal data for any promotional or marketing purpose.
The types of personal data that CCL would use and provide for direct marketing purposes as described above are your name and relevant contact details, although we may possess additional personal data.
If your consent is required, and you provide such consent, you may thereafter withdraw your consent to the use and provision to a third party by CCL of your personal data for direct marketing purposes and thereafter CCL shall cease to use or provide such data for direct marketing purposes.
If you have provided consent and wish to withdraw it or if you prefer not to receive marketing communications from us in any form, please inform us by writing to the address in the section on “Access Rights to Personal Data” or sending us an email to dpo@commoncarecentral.com. Any such request should clearly state details of the personal data in respect of which the request is being made.
Retention of Personal Data
The Data will be retained for as long as necessary to fulfill the purpose for which the Data was collected. The Data which is no longer required will be destroyed. You have the right to access and request for permanent deletion of any personal data collected and stored by CCL.
Access Rights to Personal Data
Under PDPO, you have the right to:
verify whether CCL holds any personal data about you and to access any such data;
require CCL to correct any personal data relating to you which is inaccurate; and
enquire about CCL’s policies and practices in relation to personal data.
Request for access, correction or other queries relating to the Data should be addressed to:
The Data Protection Officer
Common Care Limited
United 2302, 23/F,
New World Tower 1
18 Queen’s Road Central
Central, Hong Kong
Email: dpo@commoncarecentral.com
CCL has the right to charge costs which are directly related to and necessary for the processing of any personal data access request.
Privacy Policy Statement
For more information on how CCL collects, uses and processes the Data, please see our Privacy Policy Statement available on our website at www.commoncarecentral.com/privacy-policy.
Changes to this PICS
CCL reserves the right to update this PICS at any time and will make available an updated PICS on our website or in writing so that you are always aware of what information we collect, how we use the information and under what circumstances the information is disclosed. Any such change, update or modification will be effective immediately upon posting.
If you have any questions about this PICS, please contact the data protection officer at dpo@commoncarecentral.com.