Hong Kong is a leading international centre of finance and technology, with an extensive network of carrier-dense data centers. These infrastructure platforms provide a secure and scalable environment for data transfer. We’re a trusted partner for numerous global enterprises and a wide range of network service providers. Our customers can interconnect into our data centers and into one of Asia’s most carrier-dense networks. This helps them to achieve their business objectives while lowering costs and improving performance.
The term “personal data” is defined in the PDPO as “any information about an identifiable natural person, including:
In principle, personal data may only be collected for a lawful purpose. The data collected should be adequate and not excessive in relation to the purpose of collection. It must also be fair and reasonable to the individual concerned and not prejudice his or her rights and freedoms. The term “identifiable” is broadly defined, and encompasses factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
Under the PDPO, data users are required to expressly inform a data subject of the purposes for which their personal data is collected and the classes of persons to whom the data may be transferred, on or before collecting such data. This is an obligation that must be fulfilled regardless of whether the data is being transferred within or outside Hong Kong. This is because the use of personal data is considered a form of transfer under the PDPO.
However, the PICS requirement is less onerous in Hong Kong than in mainland China and the EU, and even so, data users must still carefully consider the underlying grounds for the proposed transfer before proceeding to obtain consent from the individual concerned. Moreover, data transfers are only permitted if the lawful basis for the transfer is established under the PDPO.
A recent proposal by the Chinese government would bring Hong Kong’s data sharing rules in line with those of the mainland. The proposed new rules, aimed at speeding up the connection of the Greater Bay Area (“GBA”) to mainland China, will streamline the transfer of data between the two regions. This will enable the GBA to be developed into a major regional financial data exchange and help boost Hong Kong’s role as an important regional data hub.
The Hong Kong Monetary Authority (HKMA) has launched a pilot for a cloud computing interconnection infrastructure to boost data sharing in the city’s banking sector. The project, known as the Commercial Data Infrastructure (CDI), is part of the HKMA’s Fintech 2025 strategy to enhance Hong Kong’s data infrastructure and empower the industry to develop innovative financial products and solutions.
The CDI aims to replace the multiple one-to-one connections between banks and sources of commercial data, such as utility companies, with a single point of access. This will improve data sharing efficiency, security and scalability. It is also in line with the HKMA’s policy of making Hong Kong a world-leading Fintech hub.