2. Why is an employer required to identify itself in recruitment advertisements that solicit personal data from job applicants?

An employer, who collects personal data from job applicants without identifying itself (or an appointed recruitment agency) might have engaged in an act of unfair collection of personal data contrary to the requirement of data protection principle 1. It would generally not be fair for persons collecting personal data not to identify themselves when collecting data.

Secondly, personal data collected from job applicants are subject to access and correction by the person concerned (data protection principle 6). Unless exempted from doing so under the Ordinance, an employer is required to provide a copy of the data no later than 40 days after receiving a data access request. Job applicants would not be able to exercise their data access rights if they don't know the identity of the company that collected their personal data .