THE Hong Kong Computer Society (HKCS) has given only qualified support to recommendations for new legislation on data protection. The recommendations were made earlier this year by the Law Reform Commission's privacy committee. The HKCS wants greater exemptions under the law for data held for education and research purposes. But the society said it did not foresee any ''technical'' difficulties in implementing the proposals, provided there was a strong platform of principle definitions. The chairman of the HKCS's working group on computers and the law, Dr Matthew Lee, said technical issues would not become apparent until the bill had been drafted and its implementation details outlined. The Law Reform Commission's privacy sub-committee spent more than three years drafting its proposals. It had received about 120 papers from interested parties by the end of last month, which was the deadline for submissions on its proposals. Data protection laws seek to safeguard personal privacy and corporate information. In Hong Kong, their implementation has been accelerated by developments in the European Community, which will restrict the transfer of information to countries that do not have data protection and privacy laws as stringent as those in the EC. The Government has long recognised that any restrictions on the information flow could adversely affect Hong Kong trade. Hong Kong officials began looking at data protection laws in 1988. The privacy sub-committee proposals would see the creation of an Office of the Privacy Commissioner, financed by a flat-rate fee of $100 paid by all registered Hong Kong companies, no matter how large or small. These companies would be required under thelaw to furnish the commissioner ''with the main features of the data they hold''. The commissioner would have power of inspection, which would enable him to examine that data on receipt of a complaint of unfair use or invasion of privacy. Alternatively he could initiate his own inquiry on suspicion of wrong-doing. The term ''data'' for the purposes of Hong Kong's proposed law includes not only material held on computer, but paper files as well. The privacy sub-committee recommendations appear to have been quite well received. However, organisations have complained that definitions are so wide they may be open to abuse in some cases, too restrictive in others, and could be too costly for many companies to implement. ''We very much support the general tenure of the document. But there are still some implementation details that we still need to look at,'' Dr Lee said. An area of ''great concern'' to the society was the scope of exemptions in the proposed legislation. ''For example, is the keeping of a list of personal business contacts [be it in the form of a box of name cards, an address book or a pocket diary] activity exempted from the requirements of the proposed legislation?'' Dr Lee asked. The HKCS has also insisted ''that it is important to enlarge the existing exemption categories'' to include personal data held by individuals solely for the purpose of education and research. It points to the frequent use of survey and statistical exercises used constantly by institutions in routine student work. ''It would present undue obstacles to these very beneficial and necessary activities if they are not exempted from the requirements of the proposed legislation,'' Dr Lee said.