Privacy Notice

CS Asia Ltd - Privacy Notice

Last Updated: 14 May 2025

1. Our Commitment to Your Privacy

The Christian Safeguarding Centre (incorporated as CS Asia Ltd) ("we," "us," or "our") is committed to protecting the privacy and security of the personal data we handle. This Privacy Notice explains how we collect, use, store, and share personal data in compliance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

This notice covers the two main ways we process data:

As a Data User when we collect your personal information to keep you informed about our products, services, and events.
As a Data Processor when we handle child safeguarding and child protection data on behalf of other organisations who contract our services.

2. Who This Notice Applies To

This notice applies to:

Individuals who subscribe to our mailing lists or express interest in our products, services, and events.
The organisations ("Data Users") that engage our services for child safeguarding and child protection purposes. This notice also explains our role and obligations regarding the sensitive data we process on their behalf.
The individuals (including children) whose data we process as part of our child safeguarding services.

3. The Personal Data We Collect

a) For Staying Updated on Our Products, Services, and Events and to process payments:

We act as the Data User for this purpose. The types of personal data we may collect directly from you include:

Full Name
Contact Information (such as email address, phone number, and mailing address)
Payment Information

b) For Child Safeguarding and Child Protection Services:

We act as the Data Processor on behalf of our client organisations. The client organisation is the Data User and is responsible for the initial collection of this data. The data we hold and process on their behalf may include highly sensitive information, such as:

Personal details of children or other vulnerable people.
Case files and reports related to child welfare and protection.
Other sensitive information necessary for providing our contracted services.

We do not collect this child safeguarding data for our own purposes. We only process it in accordance with the instructions of the contracting organisation (the Data User) and for the fulfilment of our contractual obligations.

4. How We Use Your Personal Data

a) For Our Products, Services, and Events:

Purpose of Use: To provide you with updates, newsletters, marketing materials, and invitations to events related to our products and services.
Legal Basis: We will only use your data for this purpose with your express consent. You can withdraw your consent at any time.

b) For Child Safeguarding and Child Protection Services:

Purpose of Use: To perform the services contracted by our client organisations. This includes securely storing and managing data to assist in child protection and safeguarding efforts. Our activities are strictly governed by our contractual agreement with the Data User.

5. Data Sharing and Disclosure

We will not share your personal data with third parties except as described in this notice or where we are legally required to do so.

For our Marketing and Updates: We will not transfer your name and contact information to any other party for marketing purposes without your further express consent.
For Vulnerable People Safeguarding Services: We may disclose child (or vulnerable adults) data to the following parties, as instructed by the Data User and as required by our contractual and legal obligations:
- The organisation (Data User) that contracted our services.
- Law enforcement agencies, government bodies, or other authorised organisations where required by law or where it is necessary to protect a child's vital interests.
- Other third parties as expressly instructed by the Data Subject.
- Sub-processors such as cloud service providers for the purpose of cloud storage.

6. Data Retention

We will only retain personal data for as long as is necessary to fulfil the purposes for which it was collected.

Marketing and Update Data: We will retain your data for as long as you are subscribed to our communications. You can unsubscribe at any time, and we will securely erase your information from our active lists in a reasonable timeframe.
Child / Vulnerable People Safeguarding Data: We retain this data in accordance with the instructions of the Data User (our client organisation) and any applicable legal or regulatory requirements. Once our contractual obligation ends, we will securely return or dispose of the data as instructed by the Data User.

7. Data Security

We take all reasonably practicable steps to protect the personal data we hold from unauthorised or accidental access, processing, erasure, loss, or use. This includes physical, technical, and organisational security measures appropriate to the sensitivity of the data. We are particularly mindful of the sensitive nature of child protection data and apply stringent security protocols to safeguard it.

As a Data Processor, we are bound by contractual obligations to implement security measures that meet the requirements of the Data Users who entrust us with sensitive data.

8. Your Rights as a Data Subject

Under the PDPO, you have the right to:

Request Access to the personal data we hold about you.
Request Correction of any personal data which is inaccurate.

How to Exercise Your Rights:

For Marketing and Update Data: If you wish to access or correct the name and contact information we hold for our own marketing purposes, please send your request to our Data Protection Officer (see contact details below).
For Safeguarding Data: As we are the Data Processor for this information, any request for access or correction should be directed to the organisation that originally collected the data (the Data User). We will assist the relevant Data User in responding to your request in accordance with their instructions.

We will respond to access or correction requests within the 40-day period stipulated by the PDPO. We reserve the right to charge a reasonable fee for the processing of any data access request.

9. Direct Marketing

We will not use your personal data for direct marketing purposes without your express consent. You may opt-out of receiving marketing communications at any time by following the "unsubscribe" link in our emails or by contacting us directly.

10. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The latest version will always be available on our website.

11. Contact Us

If you have any questions or concerns about this Privacy Notice or our data handling practices, please contact our Data Protection Officer info@cs-asia.org