PCPD Model Personal Data Protection Framework for AI (2024): requirements, deadlines and compliance actions
Artificial Intelligence: Model Personal Data Protection Framework
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On this page 8 sections
In brief
PCPD Model Personal Data Protection Framework for AI (2024) is a non-binding guidance of Hong Kong SAR, issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. Its current status is guidance. Voluntary for organisations in Hong Kong deploying AI with personal data; compliance with the Personal Data (Privacy) Ordinance remains mandatory.
- Jurisdiction
- Hong Kong SAR
- Instrument type
- Guidance
- Status
- Guidance
- Legal force
- Non-binding (guidance, strategy or standard)
- Issuing body
- Office of the Privacy Commissioner for Personal Data, Hong Kong
- Adopted
- 11 June 2024
- Verification
- Verified against the official source 26 Sep 2026
What is PCPD Model Personal Data Protection Framework for AI (2024)?
Published 11 June 2024, the framework gives organisations that procure, implement and use AI systems involving personal data recommendations in four areas: AI strategy and governance (an AI governance committee, procurement due diligence), risk assessment and human oversight (a risk-based approach with levels of human involvement), customisation and implementation of AI models (data preparation, testing, security), and communication and engagement with stakeholders (transparency, explainability, opt-out, feedback). It builds on the 2021 Guidance on the Ethical Development and Use of AI.
Who does it apply to?
Voluntary for organisations in Hong Kong deploying AI with personal data; compliance with the Personal Data (Privacy) Ordinance remains mandatory.
- Sectors
- Cross-sector / all sectors
When do the requirements apply?
Dates are taken from the linked official source; a reviewer should confirm in-force and application dates before relying on them.
Official sources
-
Artificial Intelligence: Model Personal Data Protection Framework
PCPD · 11 Jun 2024 · Tier 1 source
Cite this record
AIPolicyTracker (2026). “PCPD Model Personal Data Protection Framework for AI (2024)” [AIPT-POL-0086, record version 1, verified 26 September 2026 by Bhaskar Bhatt]. https://aipolicytracker.org/id/AIPT-POL-0086 (accessed 27 October 2026). Data licensed CC BY 4.0.
Permanent id AIPT-POL-0086: it never changes or gets reused, and its address keeps working if this page moves.
Cite the official text alongside it: Artificial Intelligence: Model Personal Data Protection Framework, PCPD, https://www.pcpd.org.hk/english/resources_centre/publications/files/ai_protection_framework.pdf.
BibTeX
@misc{aipolicytracker2026_pcpdmodelpersonaldatapro,
author = {{AIPolicyTracker}},
title = {{PCPD Model Personal Data Protection Framework for AI (2024)}},
year = {2026},
howpublished = {\url{https://aipolicytracker.org/policies/hong-kong-pcpd-model-personal-data-protection-framework-for-ai}},
url = {https://aipolicytracker.org/policies/hong-kong-pcpd-model-personal-data-protection-framework-for-ai},
urldate = {2026-10-27},
note = {Data licensed CC BY 4.0. Accessed 27 October 2026}
}
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<a href="https://aipolicytracker.org/id/AIPT-POL-0086"><img src="https://aipolicytracker.org/badges/hong-kong-pcpd-model-personal-data-protection-framework-for-ai.svg" alt="AIPolicyTracker: Artificial Intelligence: Model Personal Data Protection Framework, Guidance · verified 26 Sep 2026" height="20"></a>Change history
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Record history
No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.
Record version 1: Added in the September 2026 global coverage expansion from the official source listed; reviewer to confirm dates, status and scope against the source text. Every earlier wording is in the GitHub repository.
Frequently asked questions
Is PCPD Model Personal Data Protection Framework for AI (2024) in force?
PCPD Model Personal Data Protection Framework for AI (2024) has the status "guidance"; it is not a binding law in force.
Is PCPD Model Personal Data Protection Framework for AI (2024) legally binding?
No. PCPD Model Personal Data Protection Framework for AI (2024) is a guidance; it sets expectations rather than legal requirements, unless another instrument gives it force.
Who does PCPD Model Personal Data Protection Framework for AI (2024) apply to?
Voluntary for organisations in Hong Kong deploying AI with personal data; compliance with the Personal Data (Privacy) Ordinance remains mandatory.
Where is the official text of PCPD Model Personal Data Protection Framework for AI (2024)?
The official text is published by PCPD at https://www.pcpd.org.hk/english/resources_centre/publications/files/ai_protection_framework.pdf (Artificial Intelligence: Model Personal Data Protection Framework). This record links to it and is checked against it.
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.