Your privacy is important to us. This statement outlines HKPHC privacy policy on when and how we collect personal data and how we maintain, use, store, transfer and disclose the personal data we hold. It applies to all operations within Hong Kong Psychological Center (‘HKPHC’), including visitors to our website.

It is the policy of HKPHC to respect the confidentiality of personal data and the privacy of individuals. HKPHC is bound by the Personal Data (Privacy) Ordinance (Cap. 486) and its amendment Ordinance of the laws of the Hong Kong Special Administrative Region.

The HKPHC privacy policy will be reviewed and updated from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Please regularly check our privacy policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of the HKPHC privacy policy.

The HKPHC privacy policy is based on transparency
We are committed to being open and transparent about how we manage personal information.

Types of personal data held by HKPHC
Personal data means any type of information (i) relating directly or indirectly to a specific living individual; (ii) from which enables it is practicable for the identity of the individual to be directly or indirectly ascertained; and (iii) in a form in which access to or processing of the data is practicable.
Personal data may include:

• Name

• HKID/Passport number

• Employer

• Company Badge / Name card

• Date of birth

• Contact details

• Emergency contact details

• Telephone number

• Email address

• Work experience

• Assessment test results

• Incidents at the workplace

• Other personal data obtained or received by us in connection with the services provided to you

• Personal data associated with managing queries and complaints

 

This policy applies to all data we process about you and may include some data about your physical or mental health or condition, political opinions, religious or similar beliefs, commission or allegations of an offence and other sensitive personal data. References to personal data in this policy include such sensitive personal data.

When & how personal data is collected
Personal data should not be collected unless:

• The data is collected for a lawful purpose directly related to a function or activity of HKPHC

• The collection of data is necessary for or directly related to that purpose

• The data is adequate but not excessive in relation to that purpose 

Standard personal data collection 

• We may collect personal data about you when:

• You complete the registration forms or provide any other information in connection with our services

• You call our hotline / Enquiry line

• We receive any referrals about you

• We receive results of inquiries that we might make of your employers, work colleagues, professional associations or registration body.

• We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved

• We receive any information about a workplace accident in which you are involved

• You provide us with any additional information about you

General information collected from visitors to our website 

We gather information about all our website users collectively, such as what areas users visit more frequently and what services users access the most. We only use such data anonymously and in the aggregate. This data helps us determine what is most beneficial for our users, and how we can continually create a better overall website experience for you. 

Your personal data collected on the psyhealth.center website

In some instances we may need specific data about you, such as name, email address, telephone number, language preference etc. We will collect this data if you send an enquiry or book an appointment via our website. 

Purposes for which we collect personal data 

Provision of services

Please note that it is mandatory for you to provide us with such personal data in order for us to be able to provide you with our services.

Your personal data may be used in connection with:

• Providing Psychological Services to you

• Assist with your legal or financial issues

• Session notes about you

• Any test or assessment that might be helpful to facilitate the delivery of services

• Training Services

• Our management and resolution of any complaint, inquiry or investigation in which you are involved

• Any insurance claim or proposal that requires disclosure of your personal or sensitive information

Disclosures

We may disclose your personal data for the purposes for which it is collected. Your personal data may be disclosed to:

• HKPHC’s employees and contractors located in Hong Kong (and any other countries where HKPHC may provide its services in the future) regarding delivery of our services to you

• Your family members 

• Local Emergency Services

• External providers of Training or Assessment Services

• Our insurers and brokers

• Any person with a lawful entitlement to obtain the information

• Accountants, auditors, company secretarial services and professional advisers

• IT, data, network, technology, internet, social network and business process service providers and organisations

This may include transferring your personal data to a location or country which may not offer the same level of protection of personal data as Hong Kong.

We do not disclose data about your individual visits to the HKPHC website.

Management of personal data

At HKPHC, we train our staff to respect the confidentiality of customer information and the privacy of individuals. HKPHC regard breaches of your privacy very seriously and any breach will result in disciplinary action being taken, dependent upon severity. HKPHC have appointed a Privacy Officer to ensure that our management of personal information is in accordance with this policy and the Personal Data (Privacy) Ordinance.

How do we store & protect personal data?

Safeguarding the privacy of your personal data is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium. We hold personal data in a combination of secure computer storage facilities and paper-based files and other records, and take such steps as are reasonable in the circumstances to protect the personal data we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider data is no longer needed for the fulfilment of the purpose (including any directly related purpose) for which the data is or is to be used, we will remove any details that will identify you or we will securely destroy the records.

How do we keep personal data accurate & up to date?

HKPHC takes reasonable steps to ensure that the personal information it holds and discloses is accurate up to date and complete. We recognise that personal data changes frequently with changes of address and other personal circumstances. We generally update your customer data over the telephone. Please advise your practitioner when your personal details change.

You can delete your personal information or close your file by contacting the Privacy Officer. If you do choose to close your file with HKPHC, HKPHC may retain personal information from your file as and where required by law.

Enquiries & complaints

You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches to, or otherwise contact our Privacy Officer:

Email: 

privacy@psyhealth.center

Address:

Unit 506, 5/F, Stag Building

148-150 Queen’s Road Central, Central

Hong Kong

 

We aim to acknowledge receipt of all complaints within 10 working days and aim to resolve all complaints within 40 days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time.

Access

Subject to some exceptions that are set out in the Personal Data (Privacy) Ordinance you can gain access to the personal data that we hold about you.

To make a request to access your personal data, you will need to complete an application form verifying your identity and specifying what information you require. Please contact our Privacy Officer for an application form. We will respond to your request within 40 days after the request is made and provide access to the information in the manner requested.

We may impose a moderate charge in providing access. Our Privacy Officer will discuss this with you if we refuse to provide you with access to your personal data in accordance with the Personal Data (Privacy) Ordinance, we will notify you in writing of the reasons for the refusal and the process for escalation regarding this refusal.

Correction

You may request that we correct the personal data that we hold about you if you deem it to be inaccurate, incomplete, out-of-date, irrelevant or misleading. We will:

• make the necessary correction to that data

• supply to you with a copy of the data as so corrected

• if the data has been disclosed to a third party during the 12 months immediately preceding the day on which the correction is made; and HKPHC has no reason to believe that the third party has ceased using the data for the purpose (including any directly related purpose) for which the data was disclosed to the third party, take all practicable steps to supply the third party with a copy of the data as so corrected accompanied by a notice in writing stating the reasons for the correction.

If we refuse to correct your personal data in accordance with the Personal Data (Privacy) Ordinance, we will notify you in writing of the reasons detailing our refusal to correct the information and the process for escalation regarding this refusal. If you wish to exercise your rights of correction you should contact our Privacy Officer for an application form. We will not charge you for making the request to correct your information.

Feedback

You can submit feedback in the ‘Contact’ section. Any feedback that is submitted through this area becomes the property of HKPHC. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or, with your consent, contact you for further feedback on the site.

 

• © 4 Feb, 2024