Data Centres and International Projects

Data hk is a new generation data centre that offers best-in-class technical solutions, focused on resiliency. Located within the Global Switch Hong Kong data centre, this service is designed to offer maximum power density whilst delivering high levels of security.

Among the many things that make data hk different from other providers is our ability to offer a bespoke solution that caters for your unique business requirements. Our team is always on hand to help guide you through the process and to help you select the best solution for your business.

We also have extensive experience in delivering complex international projects that involve a wide range of data centres. Whether you require a single point of presence or a multi-megawatt data hall solution, we can deliver the highest levels of availability and security for your mission-critical applications.

When a business transfers personal data outside Hong Kong, it must usually carry out a transfer impact assessment. This is a much less onerous exercise than the GDPR’s requirement to carry out a privacy impact assessment when processing personal data across borders, and it is particularly relevant for data exports from the European Economic Area (EEA) to Hong Kong. There are also a growing number of circumstances where a Hong Kong business will have to carry out a transfer impact assessment by virtue of the application of laws in other jurisdictions to its activities in Hong Kong.

A transfer impact assessment involves a review of the lawfulness of the proposed data transfer and a determination of the effect of the proposed transfer on the rights and freedoms of data subjects in Hong Kong. It is typically necessary when a data user intends to transfer personal data to a jurisdiction where the level of protection offered by its laws does not meet the standards set out in the PDPO. This assessment can be carried out either manually or by using a tool such as the APEC TIA.

In addition to the aforementioned steps, the data user must identify and adopt supplementary measures where necessary to bring the level of protection offered by its foreign counterparts up to the standards required in Hong Kong. This may include technical measures such as encryption, anonymisation or pseudonymisation and split processing. It may also include contractual provisions that impose obligations on audit, inspection and reporting, beach notification and compliance support and co-operation.

Section 33 has been widely regarded as an obstacle to the free flow of business in Hong Kong. This view was justified by the perception that it would lead to increased red tape and that it would undermine business competitiveness. However, the prevailing view now appears to be that cross-border data flows are an essential element of our economy and that there is little or no evidence that they have undermined personal data privacy. For this reason, it is unlikely that any changes will be made to the existing legal regime under section 33. Nonetheless, businesses should remain vigilant and continue to comply with the current provisions.