Hong Kong stands as one of the world's most dynamic business hubs, attracting enterprises from across the globe. But for any organization that operates in this market or handles the personal data of its residents, there is a critical piece of legislation to master: the Personal Data (Privacy) Ordinance, or PDPO.

Enacted in 1996, the PDPO is one of Asia’s longest-standing data privacy laws. It is a comprehensive framework actively enforced by the Office of the Privacy Commissioner for Personal Data (PCPD). As of 2025, with recent amendments strengthening its power, understanding your obligations under the PDPO is not just good practice—it's essential for building trust and avoiding significant penalties.

Let’s break down what every business needs to know.

The Core of the PDPO: The Six Data Protection Principles (DPPs)

The entire ordinance is built around six core principles that govern the collection, handling, and use of personal data.

DPP1: Purpose and Manner of Collection

You must collect personal data in a lawful and fair way. You must have a clear, specific purpose for collecting the data and inform the individual about this purpose on or before collection.

DPP2: Accuracy and Duration of Retention

You are required to keep personal data accurate and up-to-date. Crucially, you must not keep the data for longer than is necessary to fulfill the purpose for which it was collected.

DPP3: Use of Personal Data

You cannot use personal data for any purpose other than the one you stated at the time of collection (or a directly related one), unless you receive the individual's explicit and voluntary consent.

DPP4: Security of Personal Data

This is a critical obligation. You must take all reasonably practicable steps to protect the personal data you hold from unauthorized or accidental access, processing, erasure, loss, or use.

DPP5: Openness and Transparency

Businesses must be open about their data policies and practices. This means having a clear and accessible privacy policy that explains the kinds of personal data you hold and how it is used.

DPP6: Access and Correction Rights

Individuals have the right to request access to their personal data and to ask for corrections if the data is inaccurate. You must have a process in place to handle these requests in a timely manner.

Key Areas of Focus for Modern Businesses

Beyond the six principles, businesses should pay special attention to these areas:

• Direct Marketing: The PDPO has very specific rules for direct marketing. You must inform the individual of your intent to use their data for marketing, provide them with a clear way to opt-out, and receive their consent before using their data for this purpose.

• Cross-Border Data Transfers: Section 33 of the ordinance restricts the transfer of personal data outside of Hong Kong unless certain conditions are met (e.g., the destination has a similar data protection law). While this section is not yet fully in force, the PCPD strongly advises businesses to adopt safeguards as a matter of best practice.

• The 2021 Anti-Doxxing Amendments: Recent amendments have given the PCPD enhanced powers to investigate and prosecute "doxxing"—the malicious disclosure of an individual's personal data without their consent. This signals a move towards stricter enforcement against data misuse.

The Role of Technology in PDPO Compliance

Manually managing these principles across spreadsheets and various applications is inefficient and fraught with risk. Modern compliance requires a technological foundation that embeds privacy and security into your operations.

This is where a secure data platform like Walla becomes a strategic asset.

• Meeting Your Security Duty (DPP4): Walla helps you fulfill your obligation to protect data with core features like end-to-end encryption, granular, role-based access controls, and a secure, centralized repository.

• Managing the Data Lifecycle (DPP2): Our platform allows you to implement automated data retention and archival policies, ensuring you don't hold onto data longer than necessary.

• Streamlining Data Rights (DPP6): When a customer requests access to their data, a centralized system like Walla makes it simple to locate, verify, and provide the required information promptly and accurately.

• Building a Foundation for Secure Transfers: For any data transfers, using a platform that provides a complete audit trail and robust security gives you a strong technical foundation to prove that the data was protected at every stage.

Conclusion

The PDPO is more than a set of rules; it's a framework for building trust in a competitive and sophisticated market. By understanding the six core principles and leveraging the right technology to implement them, your business can not only ensure compliance but also demonstrate a powerful commitment to customer privacy—a true differentiator in the global economy.