Data hk — the collection and analysis of information — is a crucial tool for businesses. It helps companies make better decisions and identify opportunities for growth. It can also help government agencies develop policy and make more informed decisions. Data hk can be obtained through primary sources such as field observations and secondary sources such as published reports or industry studies. The information collected can be used for a variety of purposes, including reporting, research, or marketing.
Data is a vital resource for business and society, but it is important to protect personal information when collecting, using, or transferring it. This is especially true when transferring data across jurisdictions. To do so, companies must conduct an impact assessment that takes into account both the benefits and risks of the transfer, and the legal environments, laws and practices in each jurisdiction. The assessment should also consider the responsibilities of the data exporter in regard to protecting the transferred personal data.
The first step in assessing whether the transfer meets PDPO requirements is to determine who is a “data user”. A person is a data user if he, either alone or in common with other persons, controls the collection, holding, processing or use of personal information. This definition is more restrictive than the European definition of personal data, which includes identifiable natural persons. However, it is important to remember that even if personal data does not meet the definition of personal information under the PDPO, this does not mean that a PICS should not be provided or that issues relating to the transfer will not arise.
If the assessment reveals that the foreign law or practice does not satisfy PDPO requirements, the data exporter must consider supplementary measures to bring the level of protection up to Hong Kong standards. These might include technical measures, such as encryption or anonymisation, or contractual measures, such as additional provisions imposing obligations on audit, inspection and reporting, beach notification and compliance support and co-operation.
The PCPD recently issued a Guidance Note providing further clarity on the meaning of a data impact assessment in relation to cross-border transfers of personal data, and on the responsibilities of data users in respect of such assessments. The guidance also sets out a six step framework for conducting such an assessment, and recommends that the framework be followed. This article will examine the framework in detail and consider how it applies to data transfer between Hong Kong and non-EEA countries. It will also discuss the ongoing work of the HK-EU Data Transfer Working Group, which is helping to develop common approaches in this area.