How to Comply With Cross-Border Data Transfers in Hong Kong

Businesses engaging in cross-border data transfers face onerous obligations governed by Hong Kong law and provided comprehensive guidance. Most businesses take the approach of entering contracts with importers that contain clear and enforceable provisions – this may take the form of separate agreements, schedules to main commercial agreements or contractual provisions within main commercial arrangements.

Contracts between businesses may also contain model clauses provided by the PCPD; though not mandatory, these models can be helpful. Businesses transferring personal data outside Hong Kong often conduct what’s known as a transfer impact assessment to assess how protected that personal data will be when leaving Hong Kong – something becoming more frequent with each transfer transaction.

Under the PDPO, “data user” refers to anyone who controls the collection, holding, processing or use of personal data. A person does not qualify as a data user if their personal data does not identify an individual in a manner which makes identification practicable; this aligns with other privacy laws such as GDPR and PIPL in mainland China.

Data users must obtain the voluntary and express consent of a data subject before collecting or using their personal data in any manner outside the PICS. This requirement ensures the protection of personal data against unauthorised transfer or usage.

If a data exporter conducts a transfer impact assessment and discovers that the laws of its destination jurisdiction do not conform to those required by PDPO, they should either suspend or implement appropriate supplementary measures such as encryption, anonymisation or pseudonymisation or contractual arrangements such as audit, inspection and reporting, beach notification and compliance support and co-operation.

The PCPD’s role is to safeguard data subject rights from being undermined by transfer restrictions that do not exist and has published an extensive list of personal data likely to be transferred overseas. Furthermore, it publishes guidelines to assist businesses comply with their data transfer obligations.

Law surrounding data transfers is intricate, so businesses should not underestimate the risks. Padraig Walsh from Tanner De Witt’s Data Privacy practice group can offer guidance and advise businesses regarding transfers as well as issues they raise; contact him by e-mail or by calling +852 2368 2488 for help with data transfers or their implications.

Singapore Pools’ Social Responsibility and IT Achievements

SGP pools is an online gaming website offering advice and tips about gambling, as well as offering various bet types such as single game parlays. While such bets carry greater risk, their reward potential could be immense – in order to be successful it’s essential that you fully comprehend all rules prior to placing any bet – this way you can avoid making bad bets that will deplete your wallet!

Singapore Pools fulfills its social responsibilities as a state-owned organization by contributing a portion of its revenues to various community projects and initiatives through the Tote Board, a statutory body dedicated to allocating gambling activities’ operating surpluses toward charitable causes. Such contributions demonstrate Singapore Pools’ dedication to bettering lives of fellow citizens.

Singapore Pools contributes to its community through its Responsible Gambling Campaign, which advocates responsible and controlled gambling. This initiative is supported by their digital signage network which educates players about this practice and encourages them to gamble within their means. Furthermore, PADS4 displays event messages, lottery results and betting updates across its outlets and branches.

Singapore Pools launched their inaugural digital fundraising campaign “Community with a Heart” in 2022 with the intention of engaging the public and raising donations to Community Chest – the philanthropy and engagement arm of National Council of Social Service which provides funds to over 100 social service agencies here – through “Community with a Heart”. As of Wednesday (Feb 28), more than S$250,000 had been raised – surpassing their original target by more than half.

The company credits its success to strong leadership and involvement from its management team as well as IGT, particularly Aurora which can drive lottery innovation and profitability while providing reliability in high volume transactions. Aurora can also integrate seamlessly with other lottery systems or external data sources to streamline business processes.

Singapore Pools’ latest IT milestone was the implementation of PoolzConnect, an IP-based telephone betting system. Customers can place bets remotely and winnings will automatically be deposited into bank accounts preapproved for them, helping to minimize illegal betting activity while creating a secure e-payment gateway. Deployment was hastened thanks to senior leadership involvement as well as using a project methodology focusing on quality and speed; ultimately it has contributed towards Singapore Pools’ transformation from traditional to IT-enabled business model.