Interpath (Hong Kong) Limited (trading as ‘Interpath Advisory’) is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the Personal Data (Privacy) Ordinance (Cap. 48) as amended in 2021 (PDPO) and all other applicable data protection laws in the territories in which we operate.
This Privacy Notice sets out how we process information about you (referred to as “personal data” within this Privacy Notice), including how we collect and use this personal data and your rights in relation to this personal data.
This Privacy Notice applies to you if you are:
- a visitor to any of our websites;
- a visitor to any of our offices;
- a subscriber to our newsletter or recipient of any other marketing communications;
- our business contact or client, or an employee of a business contact or client;
- an attendee at an event, meeting or webinar hosted by us; and/or
- are otherwise provided with a copy of or link to this Privacy Notice.
This Privacy Notice applies to Interpath (Hong Kong) Limited, which trades as Interpath Advisory. Interpath (Hong Kong) Limited (“Interpath Advisory”, “we” our, or “us”), is a Hong Kong limited company with registered number 77476113.
If you have questions or comments about this Privacy Notice or how we handle personal data, please email DataPrivacy@interpath.com or send your correspondence to: Data Privacy Office, Interpath Ltd, 10 Fleet Place, London, EC4M 7RB.
We aim to respond within 30 days from the date we receive privacy-related communications.
Applicable data protection laws require us to inform you about the purposes for which we use your personal data, including the legal basis we rely upon for such use. 'Legal bases' are the legal reasons for our use of your personal data – these are set out in applicable data protection laws. We cannot use your personal data if we do not have a valid legal basis for such use.
• Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
• Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, to satisfy a legal obligation, or to pursue our legitimate interests.
• Public Sources - Personal data may be obtained from public registers (such as Company Register), news articles, sanctions lists, government intelligence and crime prevention agencies and Internet searches.
• Social and professional networking sites - If you register or login to our websites using social media (e.g., LinkedIn or Google,) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
• Business clients – Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we may review payroll data, and we often need to use personal data when dealing with company employees or when providing restructuring services. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms, policies and notices.
• Recruitment Services - We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice.
• Personal Data. Here is a list of personal data we commonly collect to conduct our business activities.
• Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
• Professional details (e.g., job and career history, educational background and professional memberships, published articles).
• Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
• Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
• CCTV at our sites may collect images of visitors.
If you give us information about someone else, or someone gives us information about you, we may add it to any personal information we already hold, and we will use it in the ways described in this Data Privacy Notice. Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this Data Privacy Notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Data Privacy Notice.
• Sensitive Personal Data. We typically do not collect sensitive or special categories of personal data about individuals other than our own employees. When we do need to process sensitive personal data from data subjects who are not our employees, it is either on the instructions of a third party, with the express consent of the individuals or as required by law. Examples of sensitive personal data we may obtain, or otherwise hold, include:
• Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
• Expense receipts that reveal affiliations with trade unions or political opinions.
• Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
• Information provided to us by our clients in the course of a professional engagement.
• Diversity and equal opportunity information volunteered by participants in recruitment processes.
• Health data where the processing is necessary to assess, monitor and control spread of infectious diseases and to provide a safe working environment.
Child data. We understand the importance of protecting the privacy of children, especially in an online environment. Our websites, services and/ or other templates and tools are not intentionally designed for or directed at children under the age of 18. We do not intentionally collect information from individuals under 18 years of age, although we may occasionally receive details about children attending performances and other events we host with their parents or guardians.
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
• Contract - We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals
• Consent - We may rely on your freely given consent at the time you provided your personal data to us particularly where your details are provided for direct marketing purposes.
• Legitimate interests - We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include:
• Delivering services to our clients - To deliver the professional services our clients have engaged us to provide.
• Monitor our IT systems – To prevent fraud or criminal activity and protect our IT systems.
• Corporate responsibility – To comply with our corporate and corporate social responsibility commitments.
• Legal obligations - We may process personal data in order to meet our legal and regulatory obligations or mandates, including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
• Providing professional advice and delivering reports related to our professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
• Promoting our professional services, products and capabilities to existing and prospective business clients.
• Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
• Personalising online landing pages and communications we think would be of interest based on interactions with us.
• Administering, maintaining and ensuring the security of our information systems, applications and websites.
• Authenticating registered users to certain areas of our sites.
• Seeking qualified candidates, and forwarding candidate career inquiries to our People team, which may be governed by different privacy terms and policies.
• Processing online requests, including responding to communications from individuals or requests for proposals, tenders and quotations.
• Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
• Travel arrangement assistance.
• Helping support clients to run a series of development programs for education and learning purposes to inform leaders in the healthcare, civil service and other industries.
• Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
• Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
• Collecting health data where the processing is necessary to assess, monitor and control the spread of infectious diseases and to provide a safe working environment.
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
• Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
• Our professional advisers, including lawyers, auditors and insurers.
• A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
• Payment services providers.
• Marketing services providers.
• Law enforcement or other government and regulatory agencies (e.g., Inland Revenue Department, Hong Kong Monetary Authority, Securities and Futures Commission) or to other third parties as required by, and in accordance with, applicable law or regulation.
• Recruitment services providers.
• Parties that support us with anti-money laundering, client conflicts and independence checks.
• Our employees, sub-contractors, other group companies, agents or service providers who work for us where required or necessary for the performance of their duties and in line with the reasons for processing set out in this Privacy Notice.
We store personal data on servers located in Australia and Asia Pacific, as well as in the UK. We may transfer personal data to reputable third-party organisations situated inside or outside these locations when we have a business reason to engage these organisations. We only transfer your data outside these locations where we are satisfied that the transfer complies with data protection law and, if legally required, appropriate safeguards are in place to ensure that your personal data is subject to safety measures equivalent to those in the country in which it is stored.
To the limited extent that it is necessary to transfer personal data outside of these locations, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data. Please contact us using the contact details set out in the Who we are and how can you contact us? section above if you wish to obtain further information concerning the safeguards we put in place, including copies of the standard contractual clauses entered into with any third parties based outside of these locations to whom we transfer personal data to.
Our websites may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our Cookies Notice.
What are your data protection rights?
• Access - You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
• Correction - You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
• Right to withdraw consent - You can withdraw consent that you have previously given to process your personal data in relation to direct marketing or can refuse consent where this is requested in order to process your personal data for an alternative purpose from the original purpose for which the data was collected. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case. This right is only available in relation to personal data that we process with your consent.
If you would like to exercise your Data Subject Rights, you can email DataPrivacy@interpath.com. No fee is required to make a request unless your request is clearly unfounded or excessive. We will respond to your request within 40 days. That period may be extended where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within 40 days of receipt of your request.
Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds or where your request is manifestly unfounded or excessive. You have a right to lodge a complaint with the Privacy Commissioner for Personal Data (“PCPD”). We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it.
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years.
Please be aware that Interpath websites may contain links to other sites, including sites maintained by third parties that are not governed by this Privacy Notice. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
If you have questions or comments about this Privacy Notice or how we handle personal data, please email DataPrivacy@interpath.com or send your correspondence to: Data Privacy Office, Interpath Ltd, 10 Fleet Place, London, EC4M 7RB.
You also have a right to lodge a complaint to the data protection supervisory authority about how we handle your personal data. The contact details for the PCPD are detailed here - PCPD
We regularly review this Privacy Notice and will post any updates to it on this webpage. All amendments will automatically take effect immediately on posting. Please check this Privacy Notice periodically to inform yourself of any changes. If you do not accept the changes made to this Privacy Notice you should immediately stop using this website.
9 April 2025
