persons, controls the collection, holding, processing or use of the data “ (emphasis added). 69. Another provision which is of relevance is section 39(l)(d)(i)(B) of the Ordinance which sets out some grounds on which the Respondent may " refuse to carry out investigation or terminate investigation, if none of the following conditions is fulfilled in respect of the act or practice specified in the complaint - (B) the relevant data user was able to control, in or from Hong Kong, the collection, holding, processing or use of the personal data " concerned 70. . Though the word "control" is not defined in the Ordinance, section 2(1) does define "processing" as "in relation to personal data, includes amending, augmenting, deleting or rearranging the data, whether by automated means or otherwise 71. From the above sections of the Ordinance, it is obvious that processing has a much restricted and narrower meaning than controlling. The control test also accords with the definition of data user which should be the criterion of the territorial competence of the Ordinance. The Appellant's contention that either "control requirement" or "process " requirement will be sufficient to satisfy the territorial requirement is without any proper basis. It is even more far fetch for Google LLC to assert that both requirements need to be satisfied before the Ordinance catches the operation. The Board finds that the submission of the Respondent on this issue is well founded and that the proper test is solely the "control " requirement . 52