HK Data: What You Need to Know
In Hong Kong, personal data is primarily protected under the Personal Data (Privacy) Ordinance. The PDPO sets out data subject rights, specific obligations to data controllers and regulates the collection, processing, holding and use of personal data through six data protection principles.
One of these principles is that personal data should not be disclosed without an individual’s consent. However, there are some exceptions, such as for the prevention of unlawful or seriously improper conduct, investigations into serious crime or in emergency situations. The PDPO also states that it’s a data user’s responsibility to ensure that any third party processors they engage do not disclose or process personal data outside of Hong Kong, except where required by law.
If a third party is engaged to process personal data, the data user must enter into a written agreement with the third party and ensure that it does not disclose or process the data in breach of the PDPO. This is particularly important when dealing with third parties that may be located in jurisdictions other than Hong Kong, or which may use cloud storage solutions.
A data governance program involves a lot of people, including employees, customers and partners. The program will also touch many business processes and decisions. It’s therefore important to clearly assign responsibilities and accountability. An excellent tool for this is the RACI model, which stands for responsible, accountable, consulted and informed. This ensures that all stakeholders are aware of their roles, responsibilities and the overall direction of the project.
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The RACI model can also help you organize your data governance team, especially if you’re working with a large number of people. When building a team, be sure to include at least one representative from each department, function and stakeholder group. This person will be able to bring a unique perspective to the team and serve as the primary point of contact for the team’s executive sponsor and steering committee. It’s also helpful to have a data governance leader, who coordinates tasks for the other members of the team and communicates their decisions. This role is generally occupied by a business analyst, IT administrator or senior business systems analyst. Ideally, this person is an experienced project manager. They will be able to build a plan for completing the necessary tasks, identify and recruit team members, and manage the overall data governance project. They will also be the point of escalation for the team when issues arise. A good data governance leader will also be able to assess and measure the effectiveness of the program, such as through ongoing data audits, metrics and ROI. This enables the team to refine their efforts and focus on key activities that drive business value.