PERSONAL INFORMATION COLLECTION STATEMENT-PURE DISTANCE LEARNING COURSES (PICS-PDLCs) OF PTI PROFESSIONAL DEVELOPMENT LIMITED (version 5.0)
Updated: August 2026
This Personal Information Collection Statement (PICS-PDLC) is provided by PTI Professional Development Limited (“PTI” or “the Company”) to prospective and registered participants of our distance learning courses, examinations, and digital portals. This statement outlines our practices in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong HKSAR (PDPO), the 2024 PCPD Model AI Protection Framework, and the August 2026 PCPD Supplementary Guidance on Agentic AI etc.
Purpose of Collection
Your personal data is collected for lawful purposes directly related to your enrollment, course delivery, qualification verification, academic certification, and the operation of our training platform. In line with the principles of data minimisation, the volume and scope of data handled are limited strictly to what is necessary, adequate, and non-excessive for executing our advanced AI and other distance learning services.
The specific purposes for processing your data include:
- Academic verification, grading calculations, course tracking, and the provision of customized distance learning curriculum paths.
- Processing user interaction metrics and conversational text logs derived from learnerengagements with our autonomous AI helpers and automated agentic tutors to perform context-specific model fine-tuning and Retrieval-Augmented Generation (RAG) grounding splits.
- Continuous tracking of user dynamics during examinations via biometric expression matching, keystroke pacing analysis, and behavioral proctoring streams to proactively mitigate automated fraud risks and anti-cheating irregularities.
- Maintaining system and data security, identifying platform anomalies, preventing data poisoning attacks, and defending against deep learning model inversion threats.
Mandatory vs. Voluntary Provision & Consequence of Refusal
Unless explicitly marked as voluntary, the provision of standard data items (e.g., formal name, active contact details, financial transaction authorizations via PayPal, and basic qualification histories) is obligatory to enable enrollment. Failure to provide mandatory data items will result in an immediate inability to register an account, register login account for Learning Management System, access digital learning modules, or receive official certification credits.
The provision of granular telemetry, ambient interactive text prompts, and supplementary peer profile details is strictly voluntary. You may opt out of supplementary data transfers at any time without affecting your standing in basic distance learning modules.
Classes of Transferees & Third-Party Vendor Governance
Personal data held by PTI will be kept strictly confidential. However, to operate our advanced AI distance learning technological ecosystems, data may be disclosed or transferred to the following classes of persons, if necessary:
- Upstream AI software providers, database maintainers, and third-party ‘AI-as-a-service’ cloud-based platform vendors, where data processing is bound under strict, legally binding Data Processing Agreements (DPAs) in compliance with DPP4(2).
- Academicor other partners, government bodies, or professional certifying authorities involved directly in the official validation of your examination credits and degrees.
- Law enforcement agencies, courts, or regulators (including the PCPD) where a statutory duty or court order necessitates disclosure, or for the prevention, preclusion, or prosecution of illegal cyber activity or doxxing acts under Section 64.
PTI strictly prohibits data transfers to third-party marketing companies. All data shared with processing networks is minimized to the bare operational threshold necessary to run localized model inferences.
Identity Card and Personal Identifier Limitations
Pursuant to the PCPD Code of Practice on the Identity Card Number and Other Personal Identifiers, PTI enforces strict limitations on recording government-issued credentials:
- The provision of your Hong Kong Identity Card (HKID) number or a visual reproduction thereof is entirely non-compulsory during our digital registration phase. PTI provides clear, less privacy-intrusive alternatives (e.g., passport numbers) to achieve learner
- PTI prohibits the collection or storage of physical or digital copies of HKID cards in anticipation of a prospective learnerrelationship or merely to safeguard against manual clerical recording errors. No copy will be accepted or retained until a participant is successfully enrolled.
- If a digital visual copy of an identity card is legally processed to provide proof of compliance with a statutory requirement, a permanent, cross-image watermark stating ‘COPY / 副本’ will be immediately applied across the entire visual representation at the exact point of upload to prevent unauthorized reproduction or systemic identity theft.
- PTI will never display a learner’s full name alongside their personal identifiers publicly. We will not issue any physical or digital access card bearing an individual’s HKID number in a legible or easily deducible form.
Modern System Safeguards & Anti-Scraping Defenses
To insulate our distance learning users from digital identity compromise, network extortion vectors, and malicious automated threats, PTI’s policy re cyber defense protocols:
- The use of third-party ‘social log-ins’ to access PTI learning platforms is strictly prohibited. This entirely blocks cross-platform consumer tracking and stops external social networks from harvesting learnerdata profiles.
- All peer portal dashboards, group chat interfaces, and interactive message systems are completely shielded behind advanced network perimeters engineered to block automated ‘data scraping’ and robotic harvest bots.
- All participant interfaces are preconfigured to the most privacy-friendly default parameters. learnerhistories, contact lists, and profile photos are completely hidden from public visibility by default.
- All active autonomous AI models are completely denied operating system administrator rights and are bounded under strict minimum runtime system permissions.
- Our systems execute automated, continuous scanning of system configuration logs to eliminate architectural security risks, backed by an immediate AI Incident Response Plan capable of instantly disconnecting affected systems and rolling back to secure network backups in the event of an anomaly alert.
Data Minimisation, Memory Pruning, & Erasure Loops
In strict compliance with DPP2 and Section 26, PTI’policy is, where necessary, to enforce hard-coded temporal retention schedules to minimize our digital footprint footprint:
- All instant messages and forum exchanges are bound to time-decayed cache schedules. learners retain an immediate execution feature to globally ‘unsend’ or permanently ‘delete for everyone’ their message records from active storage lines.
- AI models maintaining conversation histories, local caches, or long-term operational records are bound to strict expiration schedules, complemented by a routine manual engineering audit to prune, erase, or completely anonymize long-term memory registries.
- Upon formal account termination, PTI initiates an automated delete loop. This loop scrubs primary operational lines and forces complete archival shredded erasure of all residual data footprints within a standard 7-year legally bounded cycle.
Rights of Access and Correction & Human Review
Under DPP6 and Part 5 of the PDPO, you possess an un-prescribed legal right to request access to and request the correction of your personal data held in our systems. Written requests must be routed via email directly to our Data Protection Officer at pdc@the-pti.com. Verified requests will be handled and resolved within 40 calendar days.
Furthermore, to counter automation bias and comply with PCPD AI governance standards, you hold an explicit right to challenge and request a comprehensive manual human explanation of any algorithmically derived outcome, automated grading penalty, or AI-proctored examination irregularity flag. Our Advisors will perform a manual human review of the decision criteria and issue a formalized explanation statement.
Enquiries
In case of any enquiry regarding the PICS-PDLCs, our PPS or the PICS-UAR, please email pdc@the-pti.com.
Governing Laws
The PPS of PTI is construed and governed by laws of the Hong Kong SAR.