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ARTICLE · 20 FEBRUARY 2023

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Sharing Is (Not Always) Caring

Mayer Brown
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Gabriela Kennedy, Partner, and Joshua Woo, Registered Foreign Lawyer (Singapore), Mayer Brown, highlight the legal pitfalls to avoid when engaging in sharing personal data across group companies in Hong Kong.

Hong KongPrivacy

Gabriela Kennedy, Partner, and Joshua Woo, Registered Foreign Lawyer (Singapore), Mayer Brown, highlight the legal pitfalls to avoid when engaging in sharing personal data across group companies in Hong Kong.

An investigation report into a data breach involving EC Healthcare published by the Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD) on 14 November 2022 highlights the need for organisations to ensure that any use of personal data is limited to purposes notified at the time of collection, or a directly related purpose.

Any organisation obtaining personal data from another data user, particularly in the course of a merger and/or acquisition, should obtain prior explicit consent from data subjects for any cross-brand transfers or uses of personal data that go beyond purposes notified to them at the time of collection.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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