Privacy Policy Statement

For COVID-19 Vaccination Programme Booking

Statement of Policy

The Department of Health (“DH”) is committed to ensuring that all personal data collected are handled in accordance with the relevant provisions of the Personal Data (Privacy) Ordinance (“the Ordinance”). A Personal Information Collection Statement (“PICS”) will be provided to individuals on the webpage on or before the collection of personal data and you will be advised how to request access to or correction of the personal data provided.

Cookies

Cookies will not be used in any part of this website for collecting personal data. When you fill in the application form on this website, cookies including your preference on website font sizes may be stored in your computer’s hard drive, but no personal data provided during input will be included. You can still submit the application form on your computer without cookies, and you may need to adjust the font sizes of individual web pages.

We may collect the IP address of registrants when making a booking request to conduct analysis for preventing any malicious attempt to disrupt traffic to the system. Such information will only be used to optimize the use of the system and will not use the information to identify anyone.

Amendment to this Privacy Policy

DH reserves the rights to amend its prevailing Privacy Policy at any time and will upload any such amendments to this website.

For the Electronic Health System (eHealth) Registration

Statement of Policy

Electronic Health System (eHealth) is established under the Electronic Health System Ordinance (Cap. 625). It is operated by the Electronic Health Record (eHR) Office (“eHRO”), which is under the Health Bureau and led by the Commissioner for the Electronic Health Record (eHRC). The eHRO shall commit and take reasonably practicable steps to protect the privacy, confidentiality and security of the personal information in accordance with the requirements of the Personal Data (Privacy) Ordinance (PDPO) and the guidance provided in the information leaflets and other publications issued by the Office of the Privacy Commissioner for Personal Data as well as any other relevant requirements under the laws of Hong Kong.

Practice

All personal data contained in eHealth is sensitive data requiring appropriate care and protection. eHRO has adopted a series of policies, guidelines and best practices for the collection, retention, uses, disclosure, protection and facilitation of access and correction of personal data contained in the eHealth to ensure compliance with the law:

Collection of personal data

  • Personal information shall be collected from healthcare recipients (HCRs) for particular purposes.
  • Personal data for identifying and contacting the persons concerned (e.g. name, identity document number, contact information…etc.) shall be collected upon their registration in the eHealth.
  • Personal health data of any HCRs may be shared by the Healthcare Providers (HCPs) with Sharing Consent1 given voluntarily by the HCR and in relation to sharing of his/her health data in eHealth.
  • Categories of personal health data collected and shared in eHealth shall be specified by the eHRO.

Retention of personal data

  • The personal data shall be retained for uses in accordance with the Electronic Health System Ordinance. Different retention periods shall be applied to different kinds of personal data collected and held by the eHealth in accordance with its Data Retention Policy defined by the eHRO.
  • Personal data which is no longer necessary for the purpose for which it is to be used shall be erased.

Uses of personal data

  • Any personal data retained will be used as permitted in accordance with the Electronic Health System Ordinance for:
    • Improvement of efficiency, quality, continuity or integration of healthcare provided to the HCR;
    • Ascertaining whether the HCR has made an advance medical directive;
      • if the HCR has made an advance medical directive, for assessing whether an instruction in the directive is valid and applicable; or following a valid and applicable instruction in the directive;
    • Research and statistics that are relevant to public health or public safety or the development of medicine, medical treatments or medical devices2;
    • Disease control and surveillance by the Department of Health, the Hospital Authority or a health officer under Prevention and Control of Disease Ordinance (Cap. 599);
    • Carrying out of emergency rescue operations or the provision of emergency relief services;
    • The enrollment of the HCR in any health care programme authorised by the Government in which the HCR has consented to participate; or for administration or for evaluation of such a programme;
    • Formulation of public policies; and
    • Such purposes of use as permitted by or under the laws of Hong Kong e.g. uses of handling registration or withdrawal in eHealth, court proceedings, criminal investigation, etc.

Disclosure of personal data

  • Personal data collected may be disclosed, for the purposes described above, to third parties including but not limited to:
    • healthcare providers who have obtained sharing consent from the persons for sharing of their personal data for healthcare;
    • eligible person for use in connection with advance medical directives in accordance with the requirements of the Advance Decision on Life-sustaining Treatment Ordinance (Cap. 651);
    • persons approved for carrying out research, or preparing statistics, that are relevant to public health, public safety or the development of medicine, medical treatments or medical devices in accordance with the requirements under the Electronic Health System Ordinance;
    • the Department of Health, the Hospital Authority or a health officer under Prevention and Control of Disease Ordinance (Cap. 599) to carry out disease control and surveillance;
    • healthcare providers for or in connection with the carrying out of emergency rescue operations or the provision of emergency relief services;
    • an officer of the Government or a person authorised by the eHRC for (a) enrolment of the HCR in any health care programme authorised by the Government in which the HCR has consented to participate; (b) administration of such a programme; or (c) evaluation of such a programme;
    • an officer of the Government or a person authorised by the eHRC for the formulation of public policies;
    • person to whom the eHRC is required to make disclosure under any law or court order applicable in Hong Kong e.g. court proceedings, criminal investigation, referral to authority for investigation, etc.;
    • person to whom the eHRC is required to make disclosure when necessary in the public interest;
    • person or entity whom the eHRC may appoint in writing to assist in performing a function and exercising a power of eHRC pursuant to Electronic Health System Ordinance; and
    • personnel, agent, adviser, auditor, contractor or service provider engaged by us to provide services or advice (e.g. technical, security or data processing service…etc.) in connection with our operations.

Security of personal data

eHRO shall take reasonably practicable steps to ensure the security of personal data and to protect it against any unauthorised or accidental access, processing, erasure, loss or use.

Data Access Request (DAR) and Data Correction Request (DCR)

  • Any person or a relevant person on behalf of the person, may make a request to be informed where his / her personal data is held and to be supplied a copy of such personal data, and a correction of inaccuracy (if any) in the eHealth in accordance with the PDPO.
  • Requestors for DAR and/or DCR are advised to use request forms for supplying necessary information in relation to the requests.
  • A non-excessive fee is chargeable by the eHRO for complying with a data access request.
  • When handling a DAR or DCR, the eHRO shall check the identity of the requestor to ensure that he/she is the person legally entitled to make the DAR and/or DCR.
  • Please note that the eHRO may refuse to comply with a DAR and/or DCR in the circumstances specified in the PDPO.
  • DCR for HCR's personal data (e.g. name, identity document number, date of birth and gender…etc.) in eHealth may be handled by either the eHRC or any registered healthcare providers with registration function according to the relevant guidelines issued by the eHRC.
  • DCR for health data of the HCR in eHealth may be referred to and handled by respective healthcare provider who has contributed such data to the eHealth.
  • A person can submit DAR and DCR to:
    Data Protection Officer
    Electronic Health Record Registration Office
    Address: Unit 1102, 11/F, Harbourside HQ, 8 Lam Chak Street, Kowloon Bay
    Hotline: 3467 6300
    Fax: 3467 6099
    Email: ehr@ehealth.gov.hk

1 Sharing consent given to a HCP or recognized non-Hong Kong public health record system by the HCR or their SDM (if applicable) is to allow (i) the relevant HCP to obtain from eHealth any sharable data of the HCR; (ii) the relevant HCP to provide to a referral HCP any sharable data of the HCR relevant to the healthcare referral; (iii) a referral HCP to obtain from eHealth any sharable data of the HCR relevant to the healthcare referral; (iv) any sharable data of the HCR kept in eHealth to be provided to the recognized non-Hong Kong public health record system.

2 Section 29 of the Electronic Health System Ordinance has not yet come into operation.