The protection of privacy in relation to personal data is the concern of every person in SATS HK Limited (“SATS HK / the Company”). We are committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of Personal Data (Privacy) Ordinance (HK) (“PDPO”) and the General Data Protection Regulation (EU) (2016/679), if applicable. We are equally committed to ensuring that all our employees and agents uphold these obligations.
When we collect personal data from individuals, we will provide them with a Personal Information Collection Statement ("PICS") on or before the collection in an appropriate format and manner (e.g., in the same paper form or web page that collects the personal data, or in a notice posted for reference).
Kinds of Personal Data Held
The personal data that we collect typically includes but is not limited to:
- personnel records, which include job applications and staff personal details, job particulars, details of salary, payments, benefits, leave and training records, group medical and dental insurance records, mandatory provident fund schemes participation, performance appraisals, and disciplinary matters, etc.;
- personal details, which include name, gender, Chinese character code, age, identity card number, passport number, date-of-birth, preferred language, signature, dietary preference;
- contact details, which include contact phone number including personal and company phone numbers, e-mail address including business and personal e-mail addresses, fax number, postal address;
- vehicle details, which include vehicle plate number, registered owner;
- company details, which include the company name, job title, position, business registration;
- payment details, which include bank account number, credit or debit card number, expiry date and security code;
- geographic and location data details;
- sensitive personal data or special categories of personal data, which include details about your health, facial features data, sexual orientation, ethnicity, race and religious beliefs, and any criminal convictions you may have;
- other records, which include administration and operational files, personal data provided to SATS HK from individuals for participating in promotional activities, records relating to training activities organized by SATS HK, data relating to consultancy services and other services etc.
Main purposes of keeping personal data
Personal data held in:
Personnel records of employees are kept for recruitment and human resource management purposes, relating to such matters as employees' appointment, employment benefits, termination, performance appraisal and discipline, etc.
Other records are kept for various purposes which vary according to the nature of the record, such as administration of office functions and activities, seeking advice on policy or operational matters, organizing and delivering promotional and training activities, acquisition of services, etc.
SATS HK internal IT systems are developed and maintained by a local third-party service provider. The third-party service provider does not have access to personal data stored in the IT system except when it is carrying out trouble-shooting on it at SATS HK under the supervision of SATS HK staff.
SATS HK websites are developed and maintained by local third-party service providers. All SATS HK service providers are bound by contractual duty to keep confidential any data they come into contact with against unauthorized access, use and retention.
SATS HK takes appropriate steps to protect the personal data we hold against loss, unauthorized access, use, modification or disclosure.
SATS HK maintains and executes retention policies of records containing personal data to ensure personal data is not kept longer than is necessary for the fulfilment of the purpose for which the data is or is to be used. Different retention periods apply to the various kinds of personal data collected and held by SATS HK in accordance with policies in standing instructions and administration manuals.
Disclosure of personal data
The personal data collected is used for purposes directly related to the purposes for which the data was collected. In so doing, such personal data may be transferred to parties who will be contacted by us and/or other parties concerned in the performance of the Company’s functions in accordance with the purposes for which the data was collected. Other than as set out in the aforesaid, SATS HK will not disclose any personal data to any external bodies or organizations unless such disclosure is expressly provided for under the PICS under which the personal data was collected, the data subject has given permission for SATS HK to disclose such personal data or SATS HK is required or permitted to do so by law.
Data access and correction
You should make your data access request by completing the Data Access Request Form (OPS003) prescribed by the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk/english/resources_centre/publications/forms/files/Dforme.pdf) and sending the completed Form directly to the Data Protection Officer by email at firstname.lastname@example.org, or by mail to Room 608, Floor 6, Terminal 2, Asia Airfreight Terminal, 10 Chun Ping Road, HK International Airport, Lantau, Hong Kong (Attention: Data Protection Officer).
When handling a data access or correction request, SATS HK will check the identity of the requestor to ensure that he/she is the person legally entitled to make the data access or correction request. A fee is chargeable by SATS HK for complying with a data access request. A Data Protection Log Book is maintained as required under section 27 of the PDPO.