June 28, 2022

Inter Cultural Education Privacy Policy Statement

Inter Cultural Education (ICE) respects the privacy of individuals. We do our best to ensure the collection, usage, storage, transfer and disclosure of your personal data according to the Personal Data (Privacy) Ordinance. This Statement explains our policies and practices on handling personal data.

Data collection

When you are using the service of ICE, providing services to ICE, being employed by ICE, making a complaint and/or browsing the websites of ICE, your personal data may be collected, including but not limited to:

Participants / service users: Name, telephone number, mobile phone number, address, email address, date of birth, HKID number, guardian information, school, etc.

Employees / part-time instructors / any person directly or indirectly employed by ICE: the personal data provided in the job application forms, information on salary/wage, bank account number, payment records, contributions to provident fund or mandatory provident fund, leave records, training records, records on medical and claiming subsidies, performance appraisal and disciplinary action, etc.

Service providers: Name, HKID number, telephone number, address, bank account number, etc.

Complainants: the name of complainant, telephone number, email address, the content of the complaint, investigation process and result etc.

You are obliged to provide the mandatory information as listed on the forms or other necessary information for initiating the process. Otherwise, ICE may not be able to provide the service you request.

Data usage

Participants / service users: the data collected may be used for the purposes related to the participation in different programmes and activities, the issuance of receipts, collecting user feedback, conducting analyses, and any other initiatives in relation to the aims and objectives of ICE.

Employees / part-time instructors / any person directly or indirectly employed by ICE: the data collected may be used for recruitment and human resources management, such as appointment, salary/wage payment, internal transfer, performance appraisal and disciplinary action.

Service providers: the data collected may be used for payment or relevant issues.

Complainants: the data collected will be used for the investigation, reply and follow-up to the complaint.

The dissemination of news and information related to ICE and its service units would be conducted in accordance with the requirements of the Personal Data (Privacy) Ordinance, after obtaining the consent from the data subject. Should you wish to stop receiving news and information from ICE and its service units, please contact us at privacy@icehongkong.com.

Outsourcing arrangements

Some of the services of ICE, including but not limited to the development and maintenance of systems, running of classes and courses, are provided, developed and/or maintained by third-party service providers.

All providers are bound by contractual duty to keep all the personal data confidential; we also promise to take all practicable measures to protect your personal data.

Data retention

ICE will only retain your personal data within the period that retention is necessary for the fulfillment of the purposes stated during collection. Shall the personal data we keep be no longer required for the stated purposes, they will be erased within a reasonable timeframe.

Disclosure of personal data

ICE does not rent, sell, transfer or disclose your personal information with other people or non-affiliated companies except under the following circumstances:

  1. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, or any other services to ICE in connection with the operation of its business;
  2. the services requested by you is provided by the person or company concerned;
  3. with your prior consent;
  4. we believe that it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person;
  5. to satisfy any applicable law, regulation, legal process, enforceable governmental request and administrative requirements.

Protection measures

ICE takes appropriate measures to protect the personal data we hold from loss, unauthorized collection, use, modification, transfer, access or disclosure by keeping all personal data either on local storage media physically separated from the internet, accessible by authorised ICE personnel only, or by using cloud services with industry standard encryption, compliant with both the Personal Data (Privacy) Ordinance as well as the EU General Data Protection Regulation (GDPR).

Data access and correction

You should update your personal information with us shall there be any change; otherwise ICE may not be able to provide the services you request.

According to the Personal Data (Privacy) Ordinance, you have the right to access and correct your personal data and request a copy of the said data. When such requests are made, ICE will check the requestor’s identity to ensure the requestor is legally entitled to make the data access or correction request. ICE shall or may refuse to comply with a data access request in the circumstances specified in section 20 of the Ordinance, for example, the requestor fails to provide necessary information to ICE.

You can make your request by completing the Data Access Request Form (OPS003) available from the Office of the Privacy Commissioner for Personal Data (https://www.pcpd.org.hk/english/publications/files/Dforme.pdf) and/or submitting the request in writing; and sending the details to privacy@icehongkong.com. Your request will be answered in 40 days. A fee may be charged for complying with a data access request.

Revision of this Statement

ICE reserves the right to revise this Statement. Revision will be announced on ICE’s website (https://icehongkong.com/privacy). This Statement was last updated in May 2022.