Mind HK Data Privacy Policy

1. Our Commitment

Mind HK respects the personal data privacy of all individuals and pledges to be in compliance with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong so that the privacy of your personal data is protected in accordance with the standard required by law.

2. Personal Data

Personal data (“Personal Data”) is information that can be used to identify a person.  The Personal Data we collect includes:

(a) identity information such as names, contact details (including phone numbers and email addresses), addresses, identity card numbers, photos, and employment records,
(b) information on psychological wellbeing and health conditions, and
(c) technical information such as IP address or other unique device identifiers.

3. Principles

3.1 We notify those users from whom we collect data (“Data Subjects”) of the purpose for collecting their data, how this data will be used and to whom it may be transferred.  This is summarised in the Personal Information Collection Statement (PICS) which is maintained on the website.  The PICS is in the appendix of this document.

3.2 The purposes for which data may be collected and used are:

• Enrolling and providing services to you in programmes, training courses, conferences, lectures, seminars and other events;
• Sending communications including newsletters, information about programmes, seminars, conferences, events and other activities delivered by Mind HK or other agencies in conjunction with Mind HK;
• Accessing resources through the Mind HK website;
• Improving understanding of the Mind HK website traffic;
• For clinical research undertaken by Mind HK and other institutions in conjunction with Mind HK;
• For our data matching, internal business and administrative purposes;
• Assisting in law enforcement purposes, investigations by police or other government authorities and to meet requirement imposed by law;
• Reviewing and responding to any complaints or queries you may have; 
• Other purposes as notified at the time of collection; and
• Other purposes directly relating to any of the above.

3.3 The Personal Data we collect may include sensitive data requiring appropriate care and protection. We take all reasonably practicable steps to safeguard personal data from unauthorised or accidental access, processing, erasure, loss or use. Steps we take include:

• Database software is modern and kept updated
• Access to databases containing personal data is controlled through the COO and CEO of Mind HK.
• Emails to Data Subjects are sent from authorised Mind HK email addresses.
• Mass emails are sent via email software (eg Mail Chimp) that does not disclose the Data Subjects’ email addresses
• Emails to multiple people not sent via Mail Chimp are sent bcc.

3.4 We may share your Personal Data with third parties as described in this section:

1. your representatives, advisers and others you have authorised to interact with us on your behalf;
2. our staff members, officers, volunteers and practitioners who need the information to discharge their duties;
3. our affiliates within the same corporate group, third-party partners and/or business affiliates;
4. our agents, contractors, suppliers, business partners and service providers that assist us in operating the website, providing services to you, conducting relevant clinical research studies or otherwise conducting our business; 
5. our insurers, bankers, auditors and external legal advisors; and
6. competent court of law, law enforcement agencies and/or government or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.

Some persons to whom we transfer your Personal Data may be located outside Hong Kong, in locations that may not have in place data protection laws which are substantially similar to Hong Kong, and this may mean your Personal Data may not be protected to the same or similar level as that in Hong Kong.

3.5 Except as provided herein, we will not disclose your Personal Data  to any third parties unless it is necessary to provide the services, when required by law, or if we have good faith belief that such action is reasonably necessary to:

1. comply with judicial proceedings, a court order or legal process served on us;
2. protect and defend our rights, property and interests, including by enforcing our policies;
3. respond to claims that any submitted content violates the rights of third parties;
4. respond to your requests or complaints; and
5. protect the rights, property or personal safety of Mind HK, its affiliates and the public.

When we need to disclose, transfer or assign personal data to outside third-parties, we will take appropriate steps to protect the privacy of the personal data to be disclosed, transferred or assigned (for example, requiring our service providers to keep confidential any personal data with which it comes into contact).

3.6 Our service targets for the Youth Wellbeing Practitioner programme are those who are above the age of 18. We do not actively collect Personal Data from a child under 18 years of age.

3.7 Data Subjects have the choice to opt out from receiving direct marketing from us.  Direct Marketing in the context of Mind HK is:

(a) offering or advertising services (and goods, if relevant) including training, information sessions, lectures, events.
(b) the solicitation of donations or contributions.

3.8 All direct marketing email communications contain a link to the Privacy Policy and the option to unsubscribe from receiving communications.  The Data Subjects who opt out are placed on the Opt-Out List and we will not send them any communications.

3.9 If you access our information or services through the Mind HK website, you should be aware that the Mind HK website uses cookies. Information that you supply in this way will not be shared with any third party except where needed to provide a requested service. Cookies are used by Mind HK to collect statistics about the number of visits of users to our website and the users’ preference of websites and online services offered on our website. A cookie is a small file which contains anonymous information about your preferences and navigation pattern in particular sites, including your IP (internet protocol) address, browser type and the city-level location of your internet service provider, thus enabling website owners to provide more useful features for their users. If you wish to disable the cookies, you may do so by changing the setting of your browser. However, in that event, you may not be able to make full use of our website.

3.10 We use the information collected about you through the Mind HK website to improve its understanding of web visitors and to send information that you have requested or that may be considered of interest to you.  As a general rule, we will not disclose any information identifying you personally, except with your permission or where required by law.

3.11 We may retain your information for as long as necessary to fulfill the purpose(s) for which it is collected or as otherwise required to ensure compliance with applicable laws and regulations. Reasonable steps will be taken to delete or destroy the information when it is no longer necessary for any of the purposes above.

3.12 You may, on written request, access your personal data held by Mind HK.  If the personal data that Mind HK is holding is incorrect, you may request to have the information be corrected. You may also inform us that the information is incorrect, and we will correct it. You may also withdraw your consent to us using your personal data. Such requests or other queries relating to our privacy policies and practices should be addressed to:

Data Protection Officer
Mind Mental Health Hong Kong Limited
Address: Unit B, 18/F
One Capital Place
18 Luard Road.
Wan Chai, Hong Kong
Email: [email protected]

We may change this privacy policy from time to time.  The updated version will be maintained on our website.
This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.

Last version date: December 2022

Appendix

Mind HK Personal Information Collection Statement

1. Mind HK recognises its responsibilities in relation to the collection, holding, processing and use of personal data. Personal data will be collected only for lawful and relevant purposes and all reasonably practicable steps will be taken to ensure that personal data held by Mind HK is secure and accurate and to avoid unauthorised or accidental access, erasure or other use. 

2. The personal data that Mind HK may collect from time to time includes your name, contact details (including email address, address and telephone number), gender, date of birth, photos, employment records, information on psychological wellbeing and health conditions and IP address or other unique device identifiers. 

3. The provision of your personal data is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to process your application, provide services to you or include you in our marketing activities. You must ensure that all information provided to us is accurate, complete and up-to-date. Personal Data you provide that is inaccurate or incomplete may adversely affect how we engage with you in the course of our business.

4. The purposes for which data may be collected, held, processed, transferred and used are:

• Enrolling and providing services to you in programmes, training courses, conferences, lectures, seminars and other events;
• Collecting and processing donations;
• Sending communications including newsletters, information about programmes, seminars, conferences, events and other activities delivered by Mind HK or other agencies in conjunction with Mind HK;
• Accessing resources through the Mind HK website
• Improving understanding of the Mind HK website traffic;
• For clinical research undertaken by Mind HK and other institutions in conjunction with Mind HK;
• For our data matching, internal business and administrative purposes;
• Assisting in law enforcement purposes, investigations by police or other government authorities and to meet requirement imposed by law;
• Reviewing and responding to any complaints or queries you may have; and
• Other purposes as notified at the time of collection; and
• Other purposes directly relating to any of the above.

We may also obtain your Personal Data in the course of providing you with our services, including the platforms through which you sign up for our services, provide consent to us for the purposes of such services and provide information on your psychological wellbeing.  

5. We may share your Personal Information with third parties as described in this section:

a) your representatives, advisers and others you have authorised to interact with us on your behalf;
b) our staff members, officers, volunteers and practitioners who need the information to discharge their duties;
c) our affiliates within the same corporate group, third-party partners and/or business affiliates;
d) our agents, contractors, suppliers, business partners and service providers that assist us in operating the website, providing services to you, conducting relevant clinical research studies or otherwise conducting our business; 
e) our insurers, bankers, auditors and external legal advisors; and
f) competent court of law, law enforcement agencies and/or government or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.

Some persons to whom we transfer your Personal Data may be located outside Hong Kong, in locations that may not have in place data protection laws which are substantially similar to Hong Kong, and this may mean your Personal Data may not be protected to the same or similar level as that in Hong Kong.

6. The Mind HK website uses cookies with third party software. Cookies are used by Mind HK to collect statistics about the number of visits of users to our website and the users’ preference of websites and online services offered on our website. A cookie is a small file which contains anonymous information about your preferences and navigation pattern in particular sites, including your IP (internet protocol) address, browser type and the city-level location of your internet service provider, thus enabling website owners to provide more useful features for their users. If you wish to disable the cookies, you may do so by changing the setting of your browser. However, in that event, you may not be able to make full use of our website. 

7. All personal data handled by Mind HK will generally be kept confidential and will not be disclosed to any other person without your consent, except for the purposes notified in this Statement for which your Personal Data was collected or if we are required to do so by applicable laws or regulations.  We will take appropriate measures to ensure that your Personal Data is properly protected.

8. Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website and cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. Please note that Mind HK is not affiliated with, nor does it sponsor or endorse, any linking websites owned by third parties and it does not endorse any product or service offered by such linking sites.

9. Pursuant to the Personal Data (Privacy) Ordinance, you have the right to, on written request, request access to and correction of your Personal Data held by us. Such requests or other queries relating to your personal data should be addressed in writing to:

Data Protection Officer
Mind Mental Health Hong Kong Limited
Address: Unit B, 18/F
One Capital Place
18 Luard Road.
Wan Chai, Hong Kong
Email: [email protected]
We reserve the right to charge a reasonable fee for processing any access or correction request.

10. Subject to your consent, we may use the personal data you provide for direct marketing carried out by us. For the purpose of direct marketing, we intend to use your name, contact details and demographic information and market any charitable or non-profit making causes or activities offered or arranged by us and/or us in conjunction with third parties. We may not use your personal data for such purpose unless we have received your consent. 

11. You can unsubscribe from all marketing communications. All direct marketing email communications contain the option to unsubscribe from receiving communications. You may also opt-out by contacting us on [email protected] if you no longer wish any of the personal data provided to be used in any of the above described direct marketing purposes. 

We may change this privacy policy from time to time.  The updated version will be maintained on our website.

This policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this policy, the English version shall prevail.

Last version date: December 2022