Data Governance in Hong Kong

The acronym HK is the abbreviation for Hong Kong, a former British crown colony and current special administrative region of China. The territory is a popular tourist destination for many Chinese citizens, and its economy has flourished thanks to international investment. It is also home to a significant population of migrants, who make up around 20% of the city’s residents. These immigrants are a major source of skilled labour for Hong Kong, which in turn is an important economic driver.

The HK government has adopted various policies and initiatives to support the data economy, including the establishment of a unified personal data protection regime. This has resulted in enhanced compliance measures for businesses that process personal information. One such measure is the requirement to safeguard individuals’ rights and interests in cross-border data transfers.

Another policy is the establishment of an e-government portal, which provides citizens with a secure and user-friendly platform for accessing government services. This has increased transparency and helped reduce costs by enabling businesses to avoid duplication of effort and the need for human intervention in certain processes.

Aside from these policies, the HK government is looking into increasing the privacy protections for its citizens. It is considering a change in the definition of “personal data” to include not just information about an individual’s identifiability but also the context in which the information is collected. This would bring it closer in line with the GDPR.

If this change is implemented, it will be more challenging for businesses to transfer data offshore because a person’s personal data will have greater protection under PDPO than under the GDPR. It will also require more rigorous verification and enforcement of data transfer obligations. For example, a Hong Kong data user must expressly inform a person on or before collecting their personal information of the purposes for which it is collected and the classes of persons to whom the personal data may be transferred. The GDPR requires this to be done in writing.

As a result, it is crucial that any company that wants to do business in Hong Kong has the right governance frameworks in place. One key aspect is identifying and assigning roles to drive the data governance program. A RACI (responsible, accountable, consulted and informed) matrix is often used to help organize this effort. This helps ensure that all stakeholders are aware of their role and responsibilities, and is the first point of escalation for any issues or problems that arise.

In addition to these roles, a strong data governance program must have a vision and business case. The vision defines the goals and strategies of your program, while the business case articulates the specific benefits that will be realized. This is the rationale that will help to sell the project within your organization and to secure necessary funding. Ultimately, this will determine your program’s success or failure. A data governance program is a long-term initiative and should be treated as such.