On January 6, 2014, the Administrative Appeal Board affirmed the decision by the Privacy Commissioner in Hong Kong to issue enforcement notices to two magazines in relation to their clandestine photo-taking of artists at their private residence because the clandestine photo-taking amounted to "unfair means" by which personal data of the artists were collected and therefore contravened Data Protection Principle 1(2) under the Personal Data (Privacy) Ordinance. The Principle provides that "[p]ersonal data shall be collected by means which are (a) lawful; and (b) fair in the circumstances of the case."

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