We respect your privacy. Iron Mountain Hong Kong Limited (referred to as “Iron Mountain” or “We” or “Our” in this Privacy Notice) have developed this Privacy Notice to inform you of how We process and protect the Personal Data that We Collect, Use, or share with third parties. It also covers how Iron Mountain makes the Personal Data it holds available for access to and correction by you.
This Privacy Notice has been drafted having regard to Iron Mountain's obligations under the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong S.A.R.) (“PDPO”) which includes the Privacy Principles (collectively, the Ordinance). This Privacy Notice is a public document and has been prepared in light of Data Protection Principle (“DPP”) 1 (purpose and manner of collection of personal data) and DPP5 (information to be generally available) under the Ordinance.
Please read this Privacy Notice. By using the Iron Mountain Website, or by receiving notification from Iron Mountain on how you may access this Privacy Notice, whether by phone, email or otherwise, you are consenting to the Collection, Use and Disclosure of your Personal Data as set forth in this Privacy Notice.
1.1 Iron Mountain Collects Personal Data about customers, prospective customers, vendors, prospective vendors, contractors, job candidates, the general public (via Our CCTVs) and Website users which is reasonably necessary for, or directly related to, one or more of Our functions or activities. The Personal Data may be collected through Our Website, over the phone, or otherwise.
1.2 At or before the time, or, if that is not practicable, as soon as practicable after, We Collect your Personal Data, We will notify you of the matters required pursuant to DPP1 – by providing you with this Privacy Notice, or by notifying you of how you may access this Privacy Notice.
1.3 Iron Mountain will not Collect Personal Data secretly or in an underhanded way and will not sell your Personal Data to any third party (except in the course of a sale of the business, etc.).
2.1 Iron Mountain holds Personal Data which it has Collected for its Primary Purposes, including but not limited to:
2.2 Iron Mountain also holds Personal Data for purposes other than its Primary Purposes (Secondary Purposes). You provide your consent to us using your Personal Data for the following Secondary Purposes:
2.3 Iron Mountain may Use and/or Share your Personal Data for any Secondary Purposes not included in this Privacy Notice if:
2.4 From time to time We may Share your Personal Data with organisations outside of Iron Mountain in order to deliver the services you require or if required for other legal reasons. Your Personal Data is Shared with these organisations in relation to us providing Our services to you or to meet such other legal requirements. These organisations carry out, amongst other services, Our:
Iron Mountain adopts contractual or other means to prevent:
Furthermore We will take reasonable practicable steps to ensure that these organisations are bound by confidentiality obligations in relation to the protection of your Personal Data.
3.1 Iron Mountain only targets businesses with its services. Although Personal Data may be collected from any individual through Our website or otherwise for various purposes (i.e., to download a document, respond to a query or a job application), with respect to direct marketing purposes, We intend to use Personal Data that is collected from individuals in their official capacities and Our promoted services are clearly meant for the use of the targeted business. If these requirements are met, Iron Mountain does not need to obtain consent from this individual and the other provisions of the Act neither apply to Iron Mountain.
3.2 Should We have doubts that the collected Personal Data relates to individuals in their official capacities, We ask for consent for Using and/or Sharing any Personal Data Collected from you for Direct Marketing purposes in accordance with the Act, whether Collected via telephone, the Website, or otherwise, but subject to the terms of this Privacy Notice.
3.3 In each Direct Marketing communication, We will include a:
3.4 Should you Opt Out, We will stop Using and/or Disclosing your Personal Data for Direct Marketing purposes.
We take reasonable precautions to ensure that the Personal Data We Collect, Use and Share is complete, relevant and up-to-date.
However, the accuracy of that information depends to a large extent on the information you provide. That's why We recommend that you:
5.1 Iron Mountain will take reasonable steps to protect your Personal Data from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify Personal Data once it is no longer needed for any purpose for which it may be Used or Shared in accordance with DPP 2 (accuracy and duration of retention of personal data).
5.2 Iron Mountain will not attempt to match de-identified or anonymous data Collected through surveys or such online devices as "cookies", with information identifying an individual, without notifying the relevant individual.
5.3 Iron Mountain requires employees and contractors to perform their duties in a manner that is consistent with Iron Mountain' legal responsibilities in relation to privacy, including those in this Privacy Notice.
5.4 Iron Mountain will take reasonable steps to ensure that Personal Data is only accessible by people who have a genuine "need to know" as well as "right to know."
6.1 Iron Mountain will permit Our records containing your Personal Data to be accessed by you when required by the Ordinance. We may, however, refuse to provide you with access to your Personal Data if one or more of those matters contained in the Ordinance -circumstances in which data user shall or may refuse to comply with data access request)– applies, including but not limited to instances in which:
6.2 If Iron Mountain is satisfied that:
6.3 If We have refused to grant you access to your Personal Data in accordance with paragraph 6.1 above, We will still take all reasonable steps to provide you with access to your Personal Data in a way that meets both your needs and our needs.
6.4 If you:
6.5 Iron Mountain will not charge a fee for processing an access request unless the request is complex or is resource intensive. Iron Mountain does, however, reserve the right to charge an administration fee if an individual requests access to their Personal Data more than once in a three month period.
6.6 Where Iron Mountain offers online account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain Personal Data.
7.1 Iron Mountain’s Data Protection Officer will be the first point of contact for inquiries about privacy issues. If you wish to make an inquiry or complaint regarding your privacy, you should contact this person as per the details in paragraph 12.
7.2 You will find that the Iron Mountain’s Website contains a copy of this Privacy Notice.
8.1 Iron Mountain will not make it mandatory for visitors to Our Website to provide Personal Data unless such Personal Data is required to answer an inquiry or provide a service. Iron Mountain may however request visitors to provide Personal Data voluntarily to Iron Mountain (for example, as part of a competition or questionnaire).
8.2 Iron Mountain will allow you to transact with us anonymously or by using a pseudonym wherever that is reasonable and practicable.
9.1 If we send Personal Data out of Hong Kong S.A.R., Iron Mountain will take steps which are both reasonable and practicable to ensure that the recipient handles such information in accordance with the Ordinance.
9.2 Iron Mountain may Share Personal Data with a recipient without complying with 9.1 if:
Iron Mountain may, in its sole discretion, update this Privacy Notice at any time and from time to time. Any changes will be effective when posted on Our Website. Your continued use of Our Website will indicate your acceptance of any changes to the Privacy Notice. All Personal Data, Collected both before and after any changes take effect, will be subject to the terms of the then current policy, for which you will be taken to have provided consent, unless you indicate otherwise by contacting the Privacy & Compliance Team as per the details in in paragraph 12. We encourage you to refer back to this page and especially prior to providing us with any Personal Data.
Collect means gather, acquire or obtain by a lawful and fair means, information in circumstances where the individual is identifiable or identified.
Direct Marketing involves the Use and/ or Sharing of Personal Data to communicate directly with an individual to promote goods or services through written, verbal or electronic means of communication for the company that the individual is acting for and behalf of. The goods or services which are marketed may be those of Iron Mountain or those of an independent third party organisation on behalf of Iron Mountain.
Expressly Informed means the circumstance where we have provided you with a clear statement (either verbal or in writing) of the fact that that we will not be accountable under the Ordinance and you will not be able to seek redress under the Ordinance in the event that you provide consent to the disclosure of your Personal Data by us to a recipient outside of Hong Kong S.A.R. and this recipient handles your Personal Data in breach of the Ordinance.
Iron Mountain means Iron Mountain Hong Kong Limited
Opt Out means an individual's expressed request not to receive Direct Marketing communications.
Personal Data means any data (a) relating directly or indirectly to a living individual;(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. This includes, but is not limited to, an individual’s name, address, telephone number and email address.
Primary Purpose is the main reason for the Collection of any Personal Data.
Reasonable Expectation means an individual's reasonable expectation that their Personal Data might be Used or Shared for the relevant purpose.
Secondary Purpose means a purpose of Use or Disclosure other than a Primary Purpose.
Sharing generally means the release of information outside Iron Mountain, including under a contract to carry out an "outsourced function."
Use means the handling of Personal Data within Iron Mountain.
Website means the website of Iron Mountain and related webpages.
If you have questions concerning this Privacy Notice, please contact the Privacy & Compliance Team via email at email@example.com.
You can obtain further information about your privacy rights and the Ordinance from the Office of the Privacy Commissioner for Personal Data by visiting their web site at www.pcpd.org.hk.
This Privacy Notice was last updated on 19 November 2018.