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Email reply from BOC Life hi-resFirst published: 10th November 2018
In an email reply to Yui Kee's Chief Consultant, Allan Dyer, BOC Life has claimed they are not a data user for data collected via the 'Smart Bracelet'.
As reported in this newsletter, last month, the 'Smart Bracelet' is a device with an associated app that was distributed as a promotional gift by BOC Life. The User Agreement for the app, which could be accepted without reading, appeared to allow collection of excessive personal data, apparently in violation of Data Protection Principle 1.
According to their email, BOC Life purchased the device from 'Matrix Promotion Limited'. BOC Life had no involvement in the production of the device and the development of the app, and no access to any data collected by the device. Therefore, BOC Life concludes that they are not the data user for data collected by the device.
Allan Dyer commented, "Does a company have a responsibility to ensure the gifts they give out are safe? In their promotion, did BOC Life make it clear to people that the gift they were being given in return for their personal data would, itself, collect further personal data on behalf of a third party they had not heard of?"
