recommendations contained in the report of the Law Reform Commission " ( the LRC") on Reform of the Law Relating to the Protection of Personal Data published in 1994 ("the LRC Report") (see paragraph 34 on page 723 of Commissioner ofPolice v Privacy Commissioner for Personal Data [2012] 3 HKLRD 710). 34. On the one hand, chapter 2.1 (i) (under the title: “information " privacy in the international context ) of the LRC Report provides that one of the international aspects of information privacy of which local legal reforms must be cognisant is Uinternationally recognised data protection principles and the development and implications of transborder dataflow regulation ” . Chapter 2.2 (under the same title) then provides that such recommendations are based on the Organisation for Economic Co" operation and Development ( OECD") Guidelines on the Protection of Privacy and Transborder Flows of Personal Data ("the OECD Guidelines (1980)"). 35. Chapter 2.9 (under the title: “international initiatives to rationalise protection of information privacy) of the LRC Report provides that the OECD "is primarily concerned with the economic development of its member states [...] including not only many European countries but also the United States, Australia, New Zealand and Japan”. It also states the initiative to be “in an effort to introduce a rationalisation of the international regulation of data flows". The OECD Guidelines (1980) were developed by experts and became applicable in 1980. 36. Paragraph la (under the title: “general definitions") of the OECD Guidelines (1980) provides for a term, “data controller”, which means “a 25

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