A few weeks ago, the Chinese data protection authority and Hong Kong’s privacy watchdog signed a new cross-border deal that will allow for easier transfer of personal data between the two jurisdictions. The agreement aims to increase data flow from the mainland and reinforce Hong Kong’s role as a regional data hub.

The new deal should provide some relief to businesses that rely on the free flow of data, particularly in industries such as artificial intelligence, which require massive amounts of information to analyse. This increased data flow will also support Hong Kong’s efforts to connect the Greater Bay Area (GBA) and enhance its status as a regional financial services and technology hub.

However, with restrictions on international data transfers remaining in place, businesses need to remain vigilant of the obligations and risks arising from data transfer. Padraig Walsh from Tanner De Witt’s Data Privacy team explains some of the key issues to consider.

In Hong Kong, the obligation to fulfil a range of core data user obligations triggered by collecting personal data includes DPP1 (Purpose and collection of personal data) and DPP3 (Use of personal data). The PICS should disclose the classes of persons to whom the personal data may be transferred and must obtain the voluntary and express consent of the data subject before the information can be used for a purpose not contemplated in the original PICS. This requirement is a common ground for data transfers, but should be kept in mind as it is not explicitly included in the definition of “use” under the PDPO.

It is also a good practice to disclose the names of the recipients of the personal data to the data subjects as part of the PICS, and this should be a trigger for reviewing the lawfulness of the transfer. In addition, when a personal data exporter agrees to the standard contractual clauses or contributes to a transfer impact assessment as set out in GDPR, it is likely that the obligation to disclose will be a legal basis for the transfer.

As a further consideration, the PDPO requires a data user to notify the data subject of any changes to their use of the personal data they have collected. Therefore, when a data transfer is made from Hong Kong to another location, it should be considered whether the original PICS needs to be amended or the transfer constitutes a new purpose that requires the statutory consent of the data subject. This is not as onerous as it might seem, as a change to the use of personal data is not necessarily a transfer and does not automatically trigger a PICS. This point is reinforced by the fact that, under AMI:HK, the PCPD has advised participants not to deny access requests on this basis. This is a welcome move, as it would avoid data transfer costs and a potential delay in responding to an access request.

Dominoes are a game-playing tool that are cousins of playing cards and allow for a number of games as well as tests of skill and patience. They were invented in the 1300s in China and have been a popular activity ever since. From dominoes used in professional gaming competition to the domino sets people set up and then knock over, domino is a versatile tool for game play that can be as simple or complex as the user wishes. The markings on a domino, known as pips, originally represented the results of throwing two six-sided dice. In modern times, however, a domino can be marked with any number of dots to indicate a specific result.

When a player drops a domino on its side, it causes the rest of the dominoes to tip over in a line. The entire line of dominoes then falls in a chain reaction that creates a large, often elaborate pattern or structure. Dominoes can be stacked to form straight lines, curved lines, grids that form pictures, or 3D structures such as towers and pyramids. Many people also use dominoes to create artistic pieces.

The first domino a person sets down on a board must be larger than the others to begin the chain reaction. If the first domino is smaller than the others, it will not be able to push other dominoes over, and the chain reaction will be stopped. This is why some players will place their pieces strategically on the board to make sure they are able to push over as many dominoes as possible.

In fiction writing, the idea of a domino effect is an excellent way to describe the effect one event can have on another. For example, if a character does something that is immoral or against societal norms, the writer must provide the logic that will give readers the right to accept the action or keep liking the character.

Using the domino effect in a scene can also help a writer create an effective plot. Whether the writer composes her manuscript off the cuff or takes time with a carefully detailed outline, a story needs to have a strong sequence of events that lead from one point to the next.

The traditional European domino set contains 28 tiles, sometimes called bones, stones, men or cards, that have a line across the face that divides it into square ends each marked with a number of spots, or dots. The backs of the pieces are blank or have a common design. The dominoes in a set must match in order to play the various games that can be played. Most people also own extended sets of dominoes that include additional ends with different numbers of spots. These extra end tiles increase the number of unique combinations to more than double the original number of dominoes in a regular set. A common extension is the double-nine set, which has 55 tiles. There are also sets that include double-12 and double-15.