Common questions
Does it constitute personal data transfer or combination if such data is transferred between different departments of the same public authority, e.g., between Department A and B of the Municipal Affairs Bureau?
QQuestions:
Does it constitute personal data transfer or combination if such data is transferred between different departments of the same public authority, e.g., between Department A and B of the Municipal Affairs Bureau?
AReply
When it is within the terms and conditions of the data controller, i.e., the public authority is legally authorized to process the data, then inter-departmental data processing does not constitute personal data transfer. However, linking the internal databases set up for different purposes may constitute data combination.
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