Privacy Policy

Introduction

We are Justice Centre Hong Kong Limited, a company limited by guarantee and incorporated in Hong Kong (“we” or “us”), with our registered address at Unit 5, 10/F, Hermes Commercial Centre, 4 Hillwood Road, Tsim Sha Tsui, Hong Kong.

Your privacy is important to us.  We are committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements under applicable laws and regulations.  We are equally committed to ensuring that all our employees, service providers and agents uphold these obligations. 

When we provide services for you or otherwise handle your personal data for our benefit, we will be the “data user” for your personal data. 

This policy applies to all of our activities where we act as a data user .  This policy explains how we collect, use, process, manage and disclose personal data within our organisation. 

For more information about us, please see the Contact details section of this policy.

How we collect personal data

We collect personal data about you in : 

• when you visit our centre
• when you attend any of our events and/or participate in any of our programmes
• when you visit our website
• when you contact us
• when you submit a query to us
• where you register to receive emails from us regarding upcoming events
• when you request for services from us (e.g. psychosocial services or legal services)
• when you attend a meeting between you and our staff
• when you partner with us to host activities or events
• when you make a donation to us
• when you respond to a survey that we run or fill in forms on one of our websites
• by tracking your use of our website
• from third parties who are entitled to disclose that information to us
• when you apply for a job, internship, fellowship, volunteer, legal clinic, or other position with us

In some cases we may be required by law to collect certain types of personal data about you.

Where we collect personal data from you, we will generally do so ourselves.  , such as through your family, medical practitioners, charitable organisations, religious organisations, social welfare organisations, government authorities or departments, representatives, or other bodies who provide services to us, or third parties who refer you to us because they think we may be of assistance.

Kinds of personal data we collect, use, hold and disclose

The kinds of personal data that we collect, use, hold and disclose about you may include:

For all persons:

• identifying information, such as your name and date of birth
• nationality (including previous country(ies) of residence)
• contact information, such as your postal address, email address and telephone number
• financial information, such as credit card, bank account or other payment details (only where this is needed to fulfil a transaction which you make with us)
• academic qualifications, work experience, specific skills (such as language abilities), contact information of references and work rights

For persons seeking our legal/psychological/other services:

• sensitive information may be collected about you. This includes, but is not limited to  medical information (including physical and mental health), racial or ethnic origin, political affiliations, sexual orientation, immigration status (including in relation to any claim(s) for non-refoulement protection you have made in Hong Kong or any other jurisdiction), education level and/or previous criminal convictions
• information in relation to any legal proceedings relating to you in Hong Kong
• information relating to the provision of welfare support to you by the Social Welfare Department, International Social Service Hong Kong Branch, or any other welfare services provider
• any other information that may be necessary or of assistance to us in providing services to you.

Without this information, we may not be able to provide you with our services or to accurately respond to queries or requests that you submit to us.

Purposes for which we collect, use and/or disclose personal data

We collect, use and/or disclose personal data for different purposes (depending on the circumstances as to how and why we engage with you).  Not all purposes will apply to all persons.  We will only collect personal data necessary for the specific purpose(s) applicable to you.

We collect, use and/or disclose personal data about you for the following purposes:

• to provide services to you, including, but not limited to services relating to:
• your claim for protection/asylum in Hong Kong (including any appeals), pursuant to the Unified Screening Mechanism (“USM”) process or otherwise
• in relation to matters involving immigration, the police, food, housing, health care, education, employment, getting married and having a family
• assisting with enquiries with regards to immigration options other than USM, including resettlement
• to provide psychosocial services
• to carry out a transaction with you (including processing any donation payments)
• to determine your eligibility to access our services
• to communicate with you on refugee issues and causes in line with our mission
• with your consent,
• to improve our website based on your information and feedback
• to answer your queries and requests
• to comply with any applicable rules, laws or regulations, regulatory policies, industry codes of practice or guidelines, judgments, orders, notices, directions or requests issued by any court, or any administrative, governmental or regulatory body, whether in Hong Kong or otherwise, including but not limited to the carrying out of audit checks, surveillance and investigations
• to carry out education and training programs for our staff including our volunteers
• to manage and resolve any complaints or issues
• to carry out planning and forecasting activities and other internal business processes
• (with your consent where applicable),

We may also collect, use and/or disclose your information for other purposes in accordance with your requests or instructions.

Research reports

In some instances for persons who are seeking legal/psychological/other services from us, we may use your personal data in the preparation of reports and in compiling aggregate data concerning USM cases and immigration cases more generally. 

In such cases, we seek to anonymise your name and personal data however there may be instances where your personal data is disclosed.    

We will only use your data in this way with your consent.  If you do not wish us to use your data in this way, please contact us using the Contact details section of this policy.

Direct marketing

We may from time to time use your personal data to send you marketing materials about our activities that we think you may be interested in (including in some cases services and events that are provided by a third party).  This may include information about fundraising and/or educational or other related activities in line with our mission.

Marketing material may be in various forms, including advertisements, special event notifications or newsletters and delivered via various methods including but not limited to email, instant messaging, and telephone.

We may not use your personal data in this manner unless we have received your consent.

We may use your following personal data for the purpose of direct marketing: 

• identifying information, such as your name and
• contact information, such as your postal address, email address and telephone number
• other personal data that may be relevant to services and/or events that we or a third party provide

 We may also use and disclose your information for other purposes in accordance with your requests or instructions.

People to whom we may disclose personal data

We may share personal data about you with:

For all persons:

• our internal staff who need the information to discharge their duties (including for employment purposes)
• our
• payment system operators (to the extent we accept a donation from you only)

For persons seeking and/or receiving legal/psychological/other services:

• your representatives, advisers and other professionals you have authorised pursuant to our “Authority” notice to interact with us on your behalf, including, but not limited to:
• the Duty Lawyer Service (including court liaison officer and/or duty lawyer and/or pilot lawyer scheme lawyer)
• other lawyer(s) (whether a solicitor or barrister)
• the Legal Aid Department, Social Welfare Department, International Social Service Hong Kong Branch, Hospital Authority, Immigration Department, and/or Torture Claims Appeal Board, the United Nations High Commissioner for Refugees (‘UNHCR’),
• legal volunteers who have signed our “agreement for volunteer placement” form
• professional advisers who we engage to provide advice including medical practitioners and external lawyers/legal representatives
• our funders and donors
• government authorities who ask us to disclose that information or which we have requested personal information from, or to other people as required by law, including:
• the Director of Immigration and/or their departmental staff (including any immigration office(s)
• the Torture Claims Appeal Board
• the Social Welfare Department
• the Legal Aid Department
• the Hospital Authority
• any other government or court officials

We may also collect, use and/or disclose your information to other organisations in accordance with your requests or instructions.

We will never sell your personal data to any third party.

Cookies

We use cookies to monitor and observe your use of our websites, compile aggregate data about that use, and provide you with a more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites).  “Cookies” are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing.  Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this.  While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses cookies to help the website analyse how users use our website.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.  Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.  We are not responsible for how Google handle your personal data and you are responsible for considering if you accept Google’s processing

Social media links

On our website and throughout our services, we have included links to our social media profiles.  The relevant social networks

Please refer to their privacy policies for more information.

• Facebook: https://www.facebook.com/policy.php
• Twitter: https://twitter.com/en/privacy
• Instagram: https://help.instagram.com/402411646841720

Storage and security of personal data

We generally store the personal data that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers (for example, Clio).  In particular, we may use cloud-based software systems which store data in servers located in Ireland, the United States of America, and/or Canada.  Third-party data storage providers and their services are tested, certified and endorsed as secure. 

Sometimes we also keep hard copy records of this personal data in physical storage facilities. 

We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that you become aware of.

We also take steps to monitor access to and modification of your information by our staff, and ensure that our staff are aware of and properly trained in their obligations for managing your privacy.

Retention of personal data

Your personal data will only be kept as long as required for the purposes for which such personal data was collected, used and/or disclosed, or for any legal or business purposes.

At our discretion, we may retain personal data for longer than the said period if we consider it necessary or desirable to do so to meet our legal or regulatory obligations. 

Your consent

By using our website, providing personal data, attending our events, contacting us, and/or using any of our services, you agree that:

• you consent to this privacy policy, as updated from time to time; and
• if you have provided personal data to us relating to any other person, you:
• have a right to provide that information;
• have provided a copy of this privacy policy, as updated from time to time, to that person; and
• each such person has agreed to those terms.

What are your rights over your personal data?

You have a number of rights in relation to the personal data that we hold about you.  These rights are subject to certain exemptions and do differ across the jurisdictions in which we operate.  To exercise these rights, please contact us using the Contact details section of this policy.

Request access to the personal data we hold about you

You have the right to access any of the personal data that we hold about you and under Hong Kong law, we reserve the right to charge you a reasonable fee.

To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity.  There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality.  In these cases we will let you know why we cannot comply with your request.

Even if you do not request access to and/or correct your personal data held by us, if we are satisfied that, having regard to the reasons for which we hold your personal data, that personal data is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

Right of correction

If the information we hold about you is inaccurate, you have the right to have this information correction.  You may also request that we restrict the processing of that information.

Complaints

We try to meet the highest standards in order to protect your privacy. 

However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our privacy compliance team using the Contact details section of this policy.

We will make a record of your complaint and refer it to our senior management team for further investigation.  We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you can lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (“PCPD”).

You may contact the PCPD using the below details:

Office of the Privacy Commissioner for Personal Data, Hong Kong

Unit 1303, 13/F, Dah Sing Financial Centre,

248 Queen’s Road East

Wan Chai

Hong Kong

            Phone: +852 2827 2827

            Fax: +852 2877 7026

            Website: www.pcpd.org.hk

Hyperlinks

We may provide hyperlinks from this website to websites of other organisations or associated companies.

The privacy policies of others may differ significantly from this policy.  Therefore, we encourage you to read the privacy policies of each and every website that you interact with.

Review of this policy

We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations. 

The latest version of this policy will always be the version that is available on our website. 

We encourage you to review this policy whenever you access or use our website to stay informed about our information practices and the choices available to you.

Contact details

The accuracy and security of your information is important to us.  If you:

• do not want us to use your personal data in the manner set out in this policy;
• need to advise us of any changes to your personal data;
• would like to exercise a right granted under this policy or applicable law; or
• if you would like any more information about the way in which we collect and use your personal data,

please contact by mail at:

Unit 5, 10/F, Hermes Commercial Centre, 4 Hillwood Road

Tsim Sha Tsui, Hong Kong

Attention: Finance & Operations Manager

Questions can also be sent by email to: info@justicecentre.org.hk