個人資料保護辦公室

Gabinete para a Protecção de Dados Pessoais

Office for Personal Data Protection

Enquiry Case Notes
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No: 0634/C/2011

Title: Collecting copies of ID cards of the participants for a competition

Content:

    Resident X informed the GPDP that some institutions requested their competition contestants to submit ID copies.
  X asked whether this complied with the Personal Data Protection Act.

Result:

    In the absence of detailed case information, the GPDP could only provide a general remark based on general personal data processing:
  In accordance with Articles 4(1)(1) and 3(1) of the Personal Data Protection Act, it also governs the data processing of the current enquiry.
  When running a competition, if contestants’ ID copies are collected, in which contained personal information like name, gender, date of birth, the organizing institution should ensure the fulfillment of the Personal Data Protection Act. This will include the legitimacy determined in Article 6, as well as the principles of data processing in Articles 2 and 5, and so forth.
  In general, because competitions and their nature vary, an institution should determine for the types of personal data to be collected, according to the processing purposes and the needs of the activities.
  An institution should determine the categories of personal data collected in accordance with the purposes of processing and the needs of the activities. Personal data should not be collected if it is unnecessary. Regarding the current inquiry, it should be analyzed based on specific information (such as the laws, regulations, statutes of the activities, etc., that are applicable to the case). Whether it is necessary for the said institutions to collect and process contestants’ ID copies, due to the absence of detailed case information, the GPDP could not determine at present if they violated the Personal Data Protection Act.

Reference:
Please refer to "Personal Data Protection Act", articles 2,3,4,5,6 .

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