The content on this website is maintained by Médecins Sans Frontières Hong Kong ("MSF", "we", "us" or "our"). If you would like to provide feedback regarding the website, please email us at: [email protected]
MSF takes your online privacy seriously, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information and in meeting the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) as amended or revised from time to time ("PDPO").
Definition of Data Protection Terms
Data means any representation of information (including an expression of opinion) in any document, and includes any personal identifier.
Data Subject means an individual who is the subject of Personal Data.
Personal Data means any Data:
- relating directly or indirectly to a living individual;
- from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
- in a form in which access to or Processing of the Data is practicable.
Data User means an individual who, either alone or jointly or in common with other persons, controls the collection, holding, Processing or use of Personal Data.
Data Processor means a person, whether within or outside of the HKSAR, who processes Personal Data on behalf of MSF and does not process the Personal Data for any of the person's own purposes.
HKSAR means the Hong Kong Special Administrative Region of the People's Republic of China.
Processing includes, in relation to Personal Data, amending, augmenting, deleting or rearranging the Data, whether by automated means or otherwise.
Data Protection Principles
Any Data User collecting and using Personal Data must comply with the following principles of good practice:
- Personal Data must be collected for a lawful purpose directly related to a function or activity of the Data User;
- Personal Data must be collected by means which are lawful and fair in the circumstances;
- Personal Data must be adequate and not excessive for the purpose for which it was collected;
- Personal Data must be accurate;
- Personal Data must not be kept longer than necessary for the purpose for which it was collected;
- Personal Data must be used only for the purpose for which it was collected;
- Personal Data must be secure from any unauthorised or accidental access, Processing, erasure, loss or use;
- Personal Data must not be transferred to Data Processors without contractual or other safeguards for the security of, and proper retention practices in relation to, the transferred Personal Data;
- Personal Data must be accessible by the Data Subject to whom it relates; and
- Data Users must maintain transparency in their practices for handling Personal Data.
Pursuant to compliance with the principles of good practice, we require that:
- any Data Processor Processing Personal Data on our behalf are contractually responsible for following good Data protection practice;
- any Data Processor Processing Personal Data on our behalf is appropriately trained to do so;
- any Data Processor Processing Personal Data on our behalf is appropriately supervised;
- any enquiries relating to the Processing of Personal Data are promptly dealt with;
- appropriate methods of Processing Personal Data are clearly communicated to any Data Processor who is Processing Personal Data on our behalf;
- any Data Processor maintains retention practices which ensure that Personal Data is not retained for longer than is necessary;
- any Data Processor maintains adequate security measures to prevent unauthorised or accidental access, Processing, erasure, loss or use of Personal Data; and
- regular reviews and audits are made of the way Personal Data is collected, stored and processed by us or on our behalf.
Collection of Personal Data
Personal Data collected by us
From time to time, we may ask you to provide us with your Personal Data in the course of your relationship with us as a donor, supporter or fundraiser. You are not obliged to provide your information to us, but if you do not, we may not be able to contact you or to process your donation, application or request. We will collect such Personal Data from you to the extent permissible under the applicable law and regulations, including the PDPO.
Typically, we collect your Personal Data in the following ways:
- from your completion of donation forms;
- from your completion of our donor surveys;
- during our street fundraising activities;
- during our fundraising telemarketing calls;
- when you make a donation;
- when you apply for all positions in the MSF office or MSF mission;
- when you enrol to our fundraising events;
- when you email us your comments, feedback, opinion or suggestions;
- when you register to participate in a discussion on our bulletin boards, forums or social media on our website; and/or
- in the course of your establishing or maintaining a donor/supporter relationship with us.
- when you subscribe MSF newsletter
- when you register an account for set-up of a fundraising web page for MSF
- when you update your information by post, fax, email, phone or through our website.
Personal Data that we may collect from you include:
- Your name;
- You mailing address;
- Your email address;
- Your phone number;
- Your fax number,
- Your gender
- Your title
- Your date of birth;
- Your Hong Kong ID card number;
- Your payment card information (when you make a donation)
- Your bank account information (when you make a donation).
- The name of your organization
Personal Data collected from third parties
From time to time, MSF may engage third party service providers to conduct some of its fundraising activities on our behalf, and in doing so, to collect Personal Data of donors and/or supporters on our behalf. These activities include:
- direct dialogue or street fundraising where the agent, contractor or third party service provider may invite people on the street to sign up to MSF as donors;
- telemarketing where the agent, contractor or third party service provider may take donation orders over the phone;
- direct marketing by post or email where the agent, contractor or third party service provider may send direct marketing materials to individuals.
In addition, we obtain Personal Data from third party marketing companies who provide databases to us for direct marketing purposes. The information provided by such third party marketing companies has been obtained lawfully, and the relevant individuals have consented to their information being provided and used by other organisations such as MSF. Please see below for more details on our direct marketing practices.
Use of Personal Data
Specific purposes will be notified to you when we collect your Personal Data. Any Processing of your Personal Data will be only for those specified purposes or for other purposes specifically permitted under the PDPO. If it becomes necessary to change the purpose(s) for which the Data is processed, we will inform you of the new purpose(s) and obtain your consent before any Processing occurs.
Typically, we collect your Personal Data for the following purposes:
- to conduct fundraising activities;
- to process any donations made by you;
- to conduct donor surveys;
- to conduct market research and for direct marketing purposes, described in more detail under the "Direct Marketing" section below;
- to issue receipts for your donation;
- to foster communications between you and MSF;
- for any purposes in connection with any claims made by or against or otherwise involving you in respect of any fundraising activities organised or held by us including, without limitation, to make, defend, analyse, investigate, process, assess, determine or respond to such claims;
- to exercise any rights we may have in connection with our fundraising activities from time to time;
- to comply, where reasonably necessary, with any court orders, law, rules, regulations, codes of practice, guidelines or requests binding on us, including without limitation to make disclosures of your Personal Data to regulators, governmental bodies, tax authorities or industry recognized bodies, all of which may be within or outside the HKSAR; and/or
- for any purposes relating to the above or any other purposes in accordance with this Policy and other policies in relation to our fundraising activities as set out in any notices or other terms and conditions made available by us to you from time to time.
From time to time, we may use your Personal Data (including your name, contact details, demographic information, information collected from donor survey, and donation history to provide you with emails, updates, invitations, newsletters, phone calls or text messages about our fundraising events and initiatives, to invite you to make a donation and/or to invite you to participate in donor survey, but only if you consent to our doing so when we collect your Personal Data.
Even if you have given us your consent to use your Personal Data for direct marketing purposes, you may withdraw your consent at any time free of charge by emailing to [email protected]
or following the instructions on how to unsubscribe which are contained in all of our email newsletters. The withdrawal of your consent will be processed and will take effect as soon as possible.
Transfer of Your Personal Data
From time to time, we may provide your Personal Data to third party Data Processors (who may be within or outside the HKSAR) to the extent necessary to achieve the purposes specified above and to the extent permissible by law. We will only transfer Personal Data to such third party Data Processors if they agree, contractually or otherwise, to comply with the procedures and policies in relation to the retention and security of Personal Data as outlined above, or if they put in place adequate and appropriate retention and security measures themselves.
Typically, we provide Personal Data to the following persons:
- contractors and third party service providers engaged in marketing, advertising or campaigning, to help us to conduct campaign analyses, prepare donation coupons, appeal letters and donor surveys;
- any agent, contractor or third party service provider who provides administrative, telecommunications, printing, information technology, payment processing, data processing or storage services to us;
- any of our auditors, legal and/or other professional advisors;
- any person to whom we are under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or voluntary arrangements binding on us including applicable regulators, governmental bodies, or industry recognised bodies (all of which may be within or outside the HKSAR) and where otherwise required by law; and/or
- subject to your consent, any agent, contractor or third party service provider who provides marketing services to us in connection with the development and promotion of our fundraising activities.
You should be aware that when you participate in any discussion on any bulletin boards or forums or use any social media plugins on our website, your written comments are entirely public. If you do disclose Personal Information on these bulletin boards, forums or social media plugins, that information can be collected and used by others and may result in unsolicited messages from third parties. Also, by participating in these forums, you should remember that you are legally liable for the material you post, including libel and copyright infringement.
Our website utilizes Google Analytics (cookies) to collect information about how our website is used. Cookies are widely used in order to provide information about users' browsing preferences to the owners of the website. Cookies allow us to improve our website and your browsing experience. You may opt-out of cookies by disabling cookie support in your browser, but doing so may prevent our website from functioning properly (for example, banner displays may not function properly) and you may not be able to utilize fully all of the website features.
What is a Cookie? A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that website's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. A cookie cannot retrieve any other Data from your hard drive or pass on computer viruses.
The cookies we store on our websites are used to:
- track the number, and type of visits to the websites and their pages, and compile anonymous, aggregated statistics on the number of users and their usage patterns, in order for us to evaluate and enhance the performance of our websites, and
- personalize the content of our websites and facilitate user movement within the websites (including without limitation by storing your preferences for screen layouts and language, and remembering passwords during a session and the country you may have elected as your country of residence).
This information is not shared with any third parties.
Disabling Cookies. Browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may opt out of being tracked by any website using Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Social Media Plugins
Our website also uses social plugins of social networking sites including facebook.com ("Facebook"), twitter.com ("Twitter"), plus.google.com (“Google+”), weibo.com (“Sina Weibo”), t.qq.com (“Tencent Weibo”), youtube.com (“Youtube”) and u.youku.com (“Youku”). The plugins can be identified by the websites' logos (e.g. a white "f" on a blue tile or a “thumbs-up” icon for Facebook, or a blue bird for Twitter), or the phrase “Social Plugin”.
You can deactivate social plugins at any time by changing your browser preferences.
Accuracy of Your Personal Data
We will take all practicable steps to ensure that the Personal Data we hold is accurate and kept up-to-date. We will therefore take reasonable and appropriate steps to check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. Personal Data which is found to be inaccurate or out of date will be destroyed. Please see the "Access and Correction Requests" section below to find out how to make a correction request.
Retention of Your Personal Data
All practicable steps will be taken to ensure that your Personal Data is not kept longer than is necessary. We will therefore destroy or erase from our systems Personal Data when it is no longer required.
Security of Your Personal Data
Once we receive your Personal Data, we will make our best efforts to ensure its security on our systems and we will take all practicable and reasonable steps to protect your Personal Data from unauthorised or accidental access, processing, erasure, loss or use.
Links to other websites
Our website contains links to other websites that are not under our control, even though they may use the MSF name or logo on their website through an agreement with us. These other websites do not necessarily follow our privacy policies, and we recommend that you read their privacy policies carefully. We cannot control, and do not accept any liability for, the content of linked sites.
Access and Correction Requests
Under and in accordance with the terms of the PDPO, you have the right to:
check whether we hold Personal Data relating to you and to access such Personal Data; and
require us to correct any Personal Data relating to you which is inaccurate.
In accordance with the terms of the PDPO, we may charge a reasonable fee for Processing any Data access and/or correction requests.
Requests for the access and/or correction of Personal Data held by us may be made in writing to:
Personal Data Protection Taskforce
22/F Pacific Plaza, 410-418 Des Voeux Road West, Sai Wan, Hong Kong or [email protected]
Nothing in this Policy shall limit your rights under the PDPO.
This Policy shall be deemed an integral part of forms and applications you may submit to MSF.
Last Update: 28 March, 2013
Médecins Sans Frontières Hong Kong
Address: 22/F, Pacific Plaza, 410 - 418 Des Voeux Road West, Sai Wan, Hong Kong
Tel: (852) 2959 4229
Fax: (852) 2337 5442