The Ordinance

Code of Practice on the Identity Card Number and other Personal Identifiers

IV. PERSONAL IDENTIFERS OTHER THAN THE IDENTITY CARD NUMBER

The following paragraphs seek to give practical effect to the Personal Data Collection Limitation Principle (Data Protection Principle 1):

4.1

Subject to paragraph 4.2, paragraphs 2.1, 2.2 and 2.3 apply with the modifications set out in paragraph 4.3 to personal identifiers other than the identity card number in the same way as they apply to the identity card number.
4.2

Where a data user has assigned a personal identifier other than the identity card number to an individual in relation to its function or activity, such personal identifier may subsequently be collected when such collection is necessary for a purpose that is directly related to that function or activity.

Note1:

This allows a data user that has assigned a personal identifier to an individual to collect that personal identifier for a purpose that is directly related to its operations. For example, a company may assign an employee number to its employees, which it may record for security purposes each time an employee enters or leaves a restricted area within the company premises.
Note2: The paragraph also allows other persons to collect the personal identifier for purposes that are directly related to the operations of the assigning data user. For example, where a company dispatches an employee to a private household to carry out a service, the householder may record the employee number of the service engineer in order to identify the employee in, say, subsequent communication with the company.

4.3

The modifications referred to in paragraphs 4.1, 4.4, 4.6 and 4.7 are as follows:-

4.3.1

references to "identity card number" are to be construed as references to "personal identifiers other than the identity card number";
4.3.2 references to the "holder" of an identity card are to be construed as references to "the individual to whom the personal identifiers relates";
4.3.3 references to "identity card" are to be construed as references to "the original of the identification document, if any, to which the personal identifier in question relates".
Note: The identification document to which a personal identifier relates is the document issued to the individual for identification purposes containing the personal identifier concerned , e.g. a passport in relation to a passport number.

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