Last updated on: Thursday, 23 August 2018

This sets out the policies and practices of South China Morning Post Publishers Limited and all subsidiaries and affiliated companies of which it forms part (“SCMP GROUP” or “We”) in relation to the handling of personal data.

Statement of Notice

We respect privacy. SCMP GROUP is committed to complying with all applicable personal data privacy laws and regulations.

When we collect and process personal data, we will ensure that there is legal basis for us to do so – including but not limited to issuing a Privacy Notice and/or fulfilling any other requirements as provided under all applicable laws.

Statement of Practice

Kinds of Personal Data Collected

We collect personal data in five broad categories below (“Categories of Personal Data”):

Subscription Records which include records containing the personal information of the subscribers of our publications, job alert services and any other subscription based products or services.

Personnel Records which include job applicants and our employees’ personal information.

Event Attendee Records which include the personal information provided by the attendees of our events such as conferences, promotion or charity activities.

Other Operational Records which include the personal data of such data subjects involved in newsgathering, security checks, cleaning, maintenance services, consultancy, technology, auditing, supplier, service provider, licensor and other data subjects providing services in relation to all aspects of our operations.

Records collected on/from Webservers which include but not limited to the email addresses, location data and other online identifiers such as IP addresses of such data subjects who visit our websites, platforms.

Main Purposes of Processing Collected Personal Data

Subscription Records are processed for the purposes of: (i) provision of subscription, job alert orders and any other subscription based products or services; (ii) billing and payment (if applicable); and (iii) conducting market research for statistical purposes.

Personnel Records are processed for the purposes of: (i) recruitment; and (ii) human resources management and employment related activities such as employment benefits, termination, performance appraisal and discipline.

Event Attendee Records are processed for the purposes of: (i) organising and managing the relevant events; and (ii) running the related competitions, prize draws and promotions.

Other Operational Records are processed for the purposes of facilitating the effective operation of our business such as newsgathering, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor and other data subjects providing services in relation to all aspects of our operations.

Records collected on/from Webservers are kept for the purposes of: (i) providing and/or improving on the news, information and related services to you; and (ii) keeping abreast of and analysing the latest trends in the global media landscape.

Data Protection Principles

All processing of personal data shall be conducted according to the data protection principles as follows:

Personal data must be processed lawfully, fairly and transparently.
Personal data can only be collected for specific, explicit and legitimate purposes.
Personal data must be relevant and limited to what is necessary for processing.
Personal data must be accurate and kept up to date with every effort to erase or correct.
Personal data must be kept in a form such that the data subject can only be identified if it is necessary for processing.
Personal data must be processed in a manner that ensures the appropriate security.

Data Inventory

We have also kept a data inventory and data flow process to determine various aspects of our data processing including:

Business processes that use personal data.
Purposes for collecting and/or using the personal data.
Source of personal data.
Processing activities.
Any data transfer, and to whom.
Any data access, correction or opt-out request.

Such data inventory would facilitate SCMP GROUP in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.

Legal Basis of Data Processing

We ensure that there is legal basis for our proce

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