POLICY EXPRESS · PE-ITIB-184 · Innovation, Technology and Industry Bureau
Data Governance and Cross-Boundary Data Flow
A voluntary contract has handled over 140 filings, yet the privacy law behind it is unchanged and breach cases have doubled.
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2 pages · English and 繁體中文 · Built on the 1134211 Framework · Facts as at 25 October 2026
The tension and our thesis
The tension
Hong Kong wants to be an international data hub, yet its main cross-boundary tool is a voluntary, one-way, personal-information contract for the Greater Bay Area, and the privacy law behind it has no reform timetable.
Our thesis
Publish a data-flow dashboard and a reform timetable, widen the contract pathway, amend the Ordinance in targeted steps and set sharing targets for departments.
Three policy problems this brief examines
- 01The cross-boundary pathway is narrow
- 02The home law lags the flows
- 03Public-sector sharing runs on principle, not targets
Each problem is developed in three layers: the fact, why it persists, and the consequence for the system.
Three options compared
A · Statute: a comprehensive data law and Ordinance reform, aligned with Mainland rules.
B · Contract route: widen the Standard Contract; leave the rest voluntary.
C · Wait and see: defer to national and international rules.
The scored comparison, the justified recommendation with its phased measures, the implementation challenges, the stakeholder assessment and the success metrics are in the full brief.
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Both pages, in English and Traditional Chinese: the introduction and background, key figures, the three policy problems, the scored options, the recommendation with its phased measures, the implementation challenges, the stakeholder assessment and the conclusion.
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Facts and figures are checked against primary sources where we could retrieve them. † marks press-only figures. (J) marks IRB judgements. Facts as at 25 Oct 2026.
Questions
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