Médecins Sans Frontières Hong Kong (MSFHK)
PRIVACY NOTICE
1. ABOUT THIS PRIVACY NOTICE
Médecins Sans Frontières Hong Kong (“MSFHK”,
“we”, “our”, “us”) respects your personal data privacy when collecting, using,
processing, storing, transferring and destructing personal data. This Privacy
Notice (“Notice”) explains our policies and practices, and applies to
information collection and use, including but not limited to, while you are
visiting and using our websites and other offline channels. It is written in
accordance with relevant data protection laws in force in places including but
not limited to Hong Kong. “Personal Data” means information relating to you or other identifiable individual. When we collect personal data
from individuals, we will provide them with a Personal Information Collection
Statement ("PICS"), or by a separate notification, on or before the
collection in an appropriate format and manner. Please read the following
carefully to understand our policy and practices on how your Personal Data will
be collected and processed. By providing your Personal Data to us, you are consenting
to this Notice, and the collection, use, transfer, storage and processing of
your Personal Data as mentioned in this Notice. If you are under the age of 18,
you must have a representative, e.g. parent or guardian, accepting this Notice
on your behalf before providing any Personal Data to us. If you’ve any questions please contact us at privacy@hongkong.msf.org
2. WHEN DO WE COLLECT INFORMATION ABOUT YOU?
We collect your personal data and other information:
DIRECTLY
You may give us personal information directly when you donate, sign up
for one of our events, apply for employment or volunteer opportunities,
communicate with us, sign up for email newsletters and leave a comment/message
on our social media accounts etc. You may also share your personal information
on emergency for REACH platform. Typically, we collect your Personal Data in
the following ways. Please note that the ways below are indicative only and
non- exhaustive:
General
Donation Related
Communications and Events Related
Human Resources Related
Emergency Support Related
INDIRECTLY
We may get your personal information via a fundraising organization or
platform if you’ve told them that you’re supporting MSFHK and with your
consent. Please check their privacy policies when you give them your
information.
SOCIAL MEDIA/NETWORKING
We may get information about you from your social media accounts or networking
sites. Facebook and Twitter are examples. We can do this if you’ve set
your account settings to give us permission. Please check your settings
and their privacy policies for more details.
COOKIES
Like most websites, we use “cookies” to identify you when you visit our
website. Our websites may contain links to other sites that may use cookie
technology. We do not have access to, or control over, these cookies.
What are cookies?
Cookies are small text files that are transferred from the website to
your computer, phone or tablet. Websites store cookies on your internet
browser (Chrome, Firefox or Internet Explorer, for example) when you
visit. Every time you return to the site and navigate around it picks up these
bits of information. There are several types of cookie and they each have
different functions and uses. Some cookies can be really helpful and most websites rely on them in order to work
properly and to understand what their users do when they visit.
Types of cookies
The four categories, from the least to the most intrusive, are:
What cookies do we use?
Controlling Cookies
You can control and/or delete cookies at any time. You can also get rid
of all the cookies already on your computer. Most web browsers
automatically accept cookies, but you should be able to change your
browser to prevent that. If you want to know how to do this
please look at the help menu on your web browser. Instructions on how to
do so will vary from browser to browser but you can find out more
information at www.aboutcookies.org.
3. WHAT INFORMATION DO WE COLLECT?
Personal data that we may collect from you:
When you donate, we may also collect your bank or credit card details in
compliance with the PCI Compliance Regulations.
We may also collect Sensitive Personal Data when you apply for field
work in MSFHK missions.
4. HOW DO WE USE YOUR INFORMATION?
As a general rule, your personal
data will not be used for any other purpose than that for which they were
voluntarily provided to us. Your personal data are shared or transferred to
third parties if such sharing or transfer is authorized by you or required
to achieve the purposes for which you have provided them to us. It means
that we may share your personal data with service providers, who help
assist us in fulfilling our purposes. For instance, by registering to our newsletter,
you consent that your personal data (name and email) be processed for the
purpose of sending you emails. Personal data may also be shared with third
parties when required by law or by a court order.
Your Personal Data may be used in the following ways, although these
situations are not exhaustive:
Save for the aforementioned ways, we will only
use your personal information where the law allows us to. We use your
personal information only where:
If you have given us consent to use your personal information for a
specific purpose, you have the right to withdraw your consent any time by
contacting us, but please note this will not affect any use of your
information that has already taken place.
How we use your data depends on why you are providing it
ONLINE/ OFFLINE FORMS AND FEEDBACK
We’ll use your personal information to respond to your questions,
requests, register you for events and react to the input on REACH.
SURVEYS
We use surveys to understand who visits our websites and how they use
it, helping us to create better content for you and make our websites
easier to use. We may ask for your email address if you’re happy to be
involved in future surveys or testing. We’ll only use this to ask you to
help us with these types of requests.
DONATIONS
We use your information to process and keep a record of your donation,
in accordance with the relevant legislation on data retention. We also use
your data to provide you with the tax documentation you need.
DIRECT MARKETING
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 unsubscribe@hongkong.msf.org 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.
SOCIAL MEDIA
We may use publicly available information from your profile to target
you with specific posts that may interest you. We’ll never ask for
personal or sensitive information on social media. We may repost or share
your posts on social media if it relates to MSFHK and our work. We may respond
to questions, queries or comments left on our social media channels. We
may use information found on your profile to help us answer these.
Check your social media accounts if you want to change the information
you make public. Our websites use sharing buttons which share our web
pages to social media platforms. Use these buttons at your own discretion.
Social media platforms may track these shares through your accounts.
RECRUITMENT & EMPLOYMENT
When you apply for employment or volunteer position in MSFHK office or
MSFHK missions, personal data submitted will be used solely for recruitment
purposes include identifying job applicants, evaluating applications,
making employment/appointment decisions, background or integrity
checks, employer references, and contacting you by phone, email or in
writing). If application is successful, your personal data will be stored
in our personnel records.
5. WHO HAS ACCESS TO YOUR DATA?
TRAINED PERSONNEL
Your information is only accessible by trained personnel, including
employees and volunteers. We regularly review who has access to your
information. As a general rule, your personal data
will only be accessible insofar as it is necessary to fulfill
the purpose for which it was collected. For instance, the data you provide
for donations will be accessible to our donations department, our
fundraising and marketing team and to service providers, if any, for the
purpose of processing your donation. We do comprehensive checks on any
contractors before we work with them. We always put a contract in place
that sets out how they manage the personal data they collect or have access to.
DATA PROCESSORS
We may use other companies to help us manage and store personal data and
to carry out certain activities on our behalf. Our main data processors'
services are listed below, but we may enlist the services of others from
time to time:
DATA TRANSFER
We operate globally and may have a need to transfer certain data to
countries outside Hong Kong. In the event the country where the data is
transferred does not provide an adequate level of protection, we make sure
to implement technical and organizational measures to protect your data.
If you are located in the European Economic
Area (“EEA”), your personal data may be transferred to countries located
outside the EEA which do not provide a similar or adequate level of protection
to that provided by countries in the EEA. Such transfers will only be made
in accordance with applicable laws including where necessary for us to
comply with our contractual obligations with you. We will take all steps
reasonably necessary to ensure that any personal data are treated securely and inaccordance with this Notice.
Should you have any questions in this respect we please contact us
at privacy@hongkong.msf.org.
POLICY TOWARDS CHILDREN
Our services are not directed to individuals under 16. We do not
knowingly collect personal information from individuals under 16. If we
become aware that an individual under 16 has provided us with personal
information, we will take steps to delete such information. Contact us if you
believe that we have mistakenly or unintentionally collected information
from an individual under 16.
6. HOW WE SHARE INFORMATION WE COLLECT
We may share personal information on aggregated or de-identified basis with
third parties for research and analysis, profiling, and similar purposes
to help us improve our services.
If you use any third-party software in connection with our services, for
example any third-party software that our website integrates with, you
might give the third-party software provider access to your account and
information. Policies and procedures of third-party software providers are
not controlled by us, and this policy does not cover how your information
is collected or used by thirdparty software
providers. We encourage you to review the privacy policies of third-party
software providers before you use the third-party software.
Our website may contain links to third-party websites over which we have
no control. If you follow a link to any of these websites or submit
information to them, your information will be governed by their policies.
We encourage you to review the privacy policies of third-party websites before
you submit information to them.
We may share your information with government and law enforcement
officials to comply with applicable laws or regulations, for example when
we respond to claims, legal processes, law enforcement, or national
security requests.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We use appropriate technical and organizational measures and precautions
in order to protect your personal data and to prevent the loss, misuse or
alteration of your personal data. For example, we use industry standard
SSL certificates in our websites, it is a global standard security technology
that enables encrypted communication between the web browser and the web
server.
We have adopted the following measures to protect the security and
integrity of your personal information:
We have put in place procedures to deal with any suspected privacy
breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.
While we implement safeguards designed to protect your information,
please note that no transmission of information on the Internet is
completely secure. We cannot guarantee that your information, during
transmission through the Internet or while stored on our systems or processed by
us, is absolutely safe and secure.
We only retain personal information for so long as it is reasonably
necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or
reporting requirements. We periodically review the basis and
appropriateness of our data retention policy.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as it’s necessary in connection
with the purposes defined above in “How do we use your information?” and
for the purpose of providing you with your tax receipt. For instance and as a general rule, we keep your email for the
purpose of sending you a newsletter until you unsubscribe.
If you request to receive no further contact from us, we'll keep the
basic information about you on our suppression list in order to avoid
sending you unwanted materials in the future, for the duration allowed by
the application legislation.
9. OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA
We need a lawful basis to collect and use personal data under data
protection law. The law allows ways to process personal data (and
additional ways for sensitive personal data). Below are relevant to the
types of processing that MSFHK carries out:
Our legitimate interests include:
10. YOUR DATA PRIVACY RIGHTS?
Visiting our sites, you acknowledge the collection and use of your
personal data by us as outlined in this Notice. If you do not agree with
the use of your personal data as set out in this Notice, please do not use
our sites.
Under the Hong Kong Personal Data (Privacy) Ordinance, you have the
right:
If you are in an EU Member State, subject to certain limitations and/or
restrictions, you have the right under the data protection laws in the EU:
You may opt out of receiving marketing materials from us. Please note,
however, that even if you opt out from receiving marketing materials from
us, you will continue to receive notifications or information from us that
are necessary for the use of our services.
As a security measure, we may need specific information from you to help
us confirm your identity when processing your privacy requests or when you
exercise your rights.
Any request as mentioned hereinabove will normally be addressed free of
charge. However, we may charge a reasonable administration fee if your
request is clearly unfounded, repetitive, or excessive.
We will respond to all legitimate requests within one (1) month.
Occasionally, it may take us longer than a month if your request is
particularly complex or if you have made a number of
requests.
Individuals in the EU also have the right to lodge a complaint about the
processing of their personal data with their local data protection
authority.
Please contact us in the first instance if you have any questions or
concerns. If you have unresolved concerns, you have the right to file a
complaint with a data protection authority in the country where you live
or work or where you feel your rights have been infringed.
If you wish to exercise one of the above rights, please contact us
through 22/F Pacific Plaza, 410-418 Des Voeux Road West, Sai Wan, Hong
Kong or privacy@hongkong.msf.org.
Where permitted by law to do so, we may charge a reasonable fee for
processing a data access request.
11. WHEN DO WE UPDATE THIS NOTICE?
We change this Privacy Notice when we need to. If we make any
significant changes in the way we treat your
personal information we’ll make this clear on our websites. By continuing to
use our website or other platform after the changes come into effect, you
agree to be bound by the revised Privacy Notice.
Last updated on 31/12/2018