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Authored by: Simon Deane and Natalie Chan
The HKMA issued guidance to AIs in November 2021 to strengthen the protection of personal data of banking customers. When sharing customers’ personal data collected through online channels (including mobile apps) with third parties for the purposes of direct marketing by the third parties, AIs should either (i) ask customers to approach the third parties directly so that the customers can provide their personal data and/or consent directly to the third parties; or (ii) redirect the customers from the AIs’ websites / mobile apps to the websites / mobile apps of the third parties so as to provide their personal data and/or consent for direct marketing by such third parties directly.
For the avoidance of doubt, third parties include group companies of AIs.
Under the redirection approach, apart from complying with the relevant provisions of the Personal Data (Privacy) Ordinance and the data protection principles, AIs should also be mindful of the following:
To access a full version of the Guidance, please see here.
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