Data hk is the newest addition to the Three HK lineup. It is primarily aimed at Indonesian domestic helpers living in Hong Kong and offers some of the most affordable 4G data packages in town. The SIM card can be purchased in selected Indonesian grocery stores in Hong Kong for HK$ 38, and comes with a credit load of 10 GB for 90 days. It also supports tethering. The SIM is a bit different from other Three HK prepaid cards in that it does not require an activation code or PIN and can be used instantly after purchasing. It does not support voice or SMS though.

The HK$ 38 SIM also contains the same speed as other 3HK 4G prepaid plans – 3.6 Mbps down and 128kbps up. However, there is a fair amount of FUP (fair use policy) involved in all of these plans, meaning that if you’re an avid data user or streamer then you may find yourself running out of bandwidth before the end of your plan. The SIM can be recharged for a further 10 GB, which will allow for unlimited data usage until the FUP expires.

As for data protection, the current PDPO does not directly regulate processors, but rather requires that the data user is liable for any breach of its obligations by a processor that processes personal data under its control. A discussion paper published earlier this year explored the possibility of a change to this, potentially expanding the definition of personal data to include any information that can be associated with an identifiable person.

Regardless of whether the changes to the law are made, companies handling personal data should be aware of their obligations, and understand how they differ from those in other jurisdictions. They should also ensure that they have appropriate controls in place to prevent unauthorised access or processing, erasure, loss, or use, and that personal data is not retained for longer than is necessary. A review of these controls should be done at least annually, or whenever there is a change to the law. It is also advisable to have a contract in place with a processor that sets out the data protections agreed between them. This will help minimise the risk of a dispute in the event that something goes wrong.