THE public consultation period for proposed radical reforms of data privacy rules has been extended to August 1, following representations from the Society of Hongkong Publishers (SHKP). If passed into law, the far-reaching recommendations will affect every business in Hongkong, whether its records are kept on computer or in a manual system. The Privacy sub-committee of the Law Reform Commission published its 200-page Consultative Document, entitled Reform of the Law Relating to Information Privacy, on March 17 and invited submissions from those affected by June 1. A 28-page summary has alsobeen subsequently published. letter dated May 18, the SHKP called for the deadline for submitting comments to be set ''no earlier than September 1''. Mark Berthold, Secretary to the Privacy sub-committee of the Law Reform Commission, said that the extension had been approved at a senior level, which is understood to mean the chairman of the commission. ''With the new deadline, interested parties will have had four and a half months from the original publication date, in March, in which to make their submissions, and we are hopeful this will prove to be adequate,'' said Mr Berthold. ''Any further extension, such as to September, would seriously delay the whole process,'' he added. Mr Cyril Pereira, chairman of the SHKP, said he was heartened by the prompt response to the extension request. ''I am pleased the sub-committee has acknowledged the complexity of its proposals and the concomitant need for detailed study of the very practical implications of their implementation,'' he said. ''This extra time should now allow the SHKP to come back to the committee with some considered and concrete proposals,'' he added. The SHKP is concerned that, if adopted in their present form, the recommendations might have and adverse impact on the subscription and mailing list aspects of the periodicals' business. List-holders would have to specify how they intended to use the data and register this intention with a newly created Privacy Commissioner. The proposed legislation would cover both the automated (i.e. computerised) and ''structured manual'' records of an estimated 300,000 Hongkong businesses. The summary document says: ''We believe that the restriction of the law to automated data would give scope for evasion and fail to take account of the continued dominance of manual records in Hongkong.'' Unstructured personal records for an individual's own use are exempted. Additionally, the proposals would require all data users to name a specific ''controller of the data'' and a ''responsible officer'' who should provide information about accessing, checking and correcting personal data where necessary. These names would also be lodged with the Privacy Commissioner. However, the direct marketing industry's greatest terror - the so-called 'opt-in' requirement - forms no part of the proposals. 'Opt-in' would have required all list-holders to contact everyone on their lists to confirm that they wished to be included, or offer the option of withdrawal. The more common 'opt-out' formula reverses the process. Consent to being listed is assumed, unless individuals specify to the contrary. The recommendations broadly follow 1981 guidelines from the Organisation for Economic Co-operation and Development (OECD) which are the basis for laws in Australia and Japan, and the voluntary guidelines adopted in Hongkong in 1988. The driving force behind Hongkong's move to upgrade guidelines into law is the threat in a draft-directive from the European Community to ban international data transfers from countries with adequate legal safeguards to those without. The European proposals are mired in scores of technical amendments, however, leading the SHKP to query the alleged haste with which Hongkong's law drafters were moving. Mr Robert Adam, managing director of Readers' Digest (Far East) and chairman of the SHKP's data privacy legislation committee, said: ''This is a 200-page document and although we are firmly in favour of data privacy laws, these are complex areas. Our legal counsel has not been able to give a full opinion as yet.''