" 20. The Ordinance imposes obligations on a data user to erase personal data. DPP 2(2) provides that all data users must take all practicable steps to ensure personal data is not kept longer than is necessary to fulfil the purpose for which it is (or is to be) used. Nonetheless, the erasure of personal data is considered unnecessary where it is in the public interest (including historical interest) for the data not to be erased. 21. In the present complaint, the Incident was widely reported by the press, and were further disseminated and discussed on various online forums. It aroused wide public concern. We therefore consider that the information on your arrest published through the Links was for journalistic purposes, and there is [no] unlawful interest in displaying the Links. 22. We understand your view that the [']right to be forgotten[,] should be established in Hong Kong. However, the Ordinance currently does not explicitly provide an individual with such right. For the sake of discussion, the right to be forgotten under Article 17 of the General Data Protection Regulation (GDPR) gives an individual a right to require organisations / businesses to delete his personal data without undue delay under specified circumstances, including where the personal data is no longer necessary in relation to the purposes for which it is collected. Nonetheless, the right to be forgotten is about empowering individuals ' reasonable control over their personal data, not about indiscriminately erasing past events. Neither is it meant to take precedence over freedom of expression and information, albeit the continued existence and 9

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