Hong Kong - privacy commissioner action against APP Developers - DAC Beachcroft

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Hong Kong - privacy commissioner action against APP Developers

Published 25 November 2014

Following the introduction by the Privacy Commissioner for Personal Data in Hong Kong (PCPD) of a guidance note entitled ‘Best Practice Guide for Mobile App Development’ (Guidelines), which had the purpose of assisting mobile app developers to comply with the Personal Data (Privacy) Ordinance (PDPO) when building apps, the PCPD has begun to take a strict line with mobile app developers.

At the end of December 2014 the PCPD initiated an open letter, signed by  21 privacy enforcement authorities around the world, to app marketplaces encouraging privacy policies being made available prior to downloads.  In January 2015 the PCPD released media statements drawing attention to four mobile app developers who had infringed the PDPO.

Currently enforcement action consists of the PCPD requiring corrective action; however this could become more serious for continuing infringement.

A copy of the Guidelines is available here.

What action could be taken to manage risks that may arise from this development?

Companies with presence in Hong Kong should ensure that if it develops or sells mobile apps in Hong Kong app stores it is familiar with and implements the best practices found in the Guidelines. Failure to do so could result in reputational damage and possible enforcement action.


Hans Allnutt

Hans Allnutt

London - Minster Court

+44 (0) 20 7894 6925

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