Pursuant to the new inspection regime under the Companies Ordinance (Cap. 622) (“CO”), correspondence addresses instead of usual residential addresses (“URAs”) of directors and partial identification numbers (“IDNs”) instead of full IDNs of directors, company secretaries and other relevant persons would be made available on the Companies Register for public inspection. Similarly, companies may withhold from public inspection the URAs and full IDNs (except the first part) on the registers they kept.
The relevant provisions were made with a view to enhancing protection of sensitive personal information while keeping up the transparency and usefulness of the Companies Register by allowing the public to continue inspecting the Companies Register for the purposes under the Companies Ordinance (Cap. 622).
The new inspection regime is implemented in three phases. Details of the phased implementation are as follows –
- Phase 1
From 23 August 2021, companies may replace usual residential addresses (“URAs”) of directors with their correspondence addresses, and replace full identification numbers (“IDNs”) of directors and company secretaries with their partial IDNs on their own registers for public inspection; - Phase 2
From 24 October 2022, URAs and full IDNs (“Protected Information”) on the Index of Directors on the Companies Register are replaced with correspondence addresses and partial IDNs for public inspection. Protected Information contained in documents filed for registration after commencement of this phase is not provided for public inspection. “Specified persons” could apply to the Companies Registry (“CR”) for access to Protected Information of directors and other persons; and - Phase 3
From 27 December 2023, data subjects could apply to CR for protecting from public inspection their Protected Information contained in documents registered with CR (“Withheld Information”), and replace such information with their correspondence addresses and partial IDNs. “Specified persons” could apply to CR for access to Withheld Information of directors and other persons.