Privacy Impact Assessment (PIA) 私隱風險評估

Compliance Resource 合規, Security Service 服務

Content (updated 2026.03)

  1. | Request for PIA Quote | PIA 報價咨詢
  2. | What is PIA and Who need to Care? | PIA 是甚麼及誰要識 ?
  3. | How to Conduct PIA? | PIA 怎麼做 ?
  4. | Our PIA Services | 我們的 PIA 服務
  5. | Assessment Methodology| 評估方法
  6. | Further Reading | 延伸閱讀
  7. | Use Case and Sample Report 用例及報告範例 01 | web link

Quote For PIA

Please use the form below to provide your requirements for a seperate PIA quotation; Or you may go CONTACT US page to reach us if you need assistance.

    PIA-1. Name of Project to conduct PIA

    PIA-2. Name of Organization to conduct PIA

    PIA-3. Organization Type

    PIA-4. SDLC stage

    PIA-5. Test Environment

    PIA-6. Conduct PIA with SRAA?

    Key Note

    Conducting SRAA and PIA during the same time-slot and SDLC stage allows PIA costs to be incorporated into the SRAA quotation, resulting in significant cost savings for your project.

    PIA-7. Data-type Involved

    In-Scope Items Sizing and Project Phase info; or additional message for us (optional)

    Your Name

    Your e-mail ( Only organization mail will be replied for authorization / validation reason )

    Your phone (optional, only if you want us to call you)

    Your Organization Name

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    What is PIA and Who need to Care 私隱風險評估是甚麼及誰要識 ?

    PIA is a terminology adopted by privacy authorities or regulations such as the followings:

    It is generally regarded as a privacy risk assessment process that evaluates an implementation or an operation involving personal data, in term of its impact upon personal data privacy with the objective of avoiding or minimizing adverse impacts.

    Core Purposes of Conducting a PIA

    1. Identify inherent privacy risks in information systems/projects that may affect personal data privacy across the entire data life cycle.
    2. Ensure data processing activities comply with Hong Kong’s PDPO and the Six Data Protection Principles (DPPs).
    3. Adopt less privacy-intrusive alternatives where possible for data-related initiatives (e.g., CCTV installation, data collection for marketing).
    4. Document privacy protection efforts to fulfill the accountability requirement for data users, and provide evidence of diligent compliance with privacy regulations.

    PIA is a mandatory compliance requirement for Hong Kong government projects and a key risk management tool for all public and private data users under the PDPO.

    (I) Mandatory PIA for Specific Hong Kong Government Initiatives & Assessments

    ▶ SRAA (Security Risk Assessment and Audit)

    PIA is a mandatory companion assessment for SRAA – the Hong Kong Government’s statutory cybersecurity assessment framework for government departments and government-funded organizations. Any project undergoing SRAA must complete a PIA to ensure cybersecurity measures align with PDPO’s data privacy requirements and protect personal data from unauthorized access or leakage.

    ▶ iAM Smart

    As Hong Kong’s official digital identity system, iAM Smart processes a large volume of sensitive personal identity data. Conducting a PIA is a mandatory legal requirement for its development, operation and any system updates, to ensure strict adherence to PDPO and the Six DPPs throughout the entire life cycle of personal data processing.

    ▶ Smart Traffic Fund

    Projects under the Smart Traffic Fund involve traffic data and location-related personal data processing. A mandatory PIA is required to comply with PDPO and Hong Kong government privacy standards for all funded initiatives.

    ▶ E-Government Projects

    All large-scale E-government projects (e.g., digital public service platforms, government data sharing systems, smart city initiative-related systems) that involve collection and processing of citizens’ personal data are required by the Hong Kong Government to conduct a PIA, to embed privacy protection into the project’s design and implementation phase.

    ▶ Automated Decision-Making Government Systems

    PIA is mandatory for government systems that make automated decisions based on personal data (e.g., public benefit approval systems, immigration clearance systems), to prevent privacy risks and algorithmic bias arising from data processing and ensure the transparency and legality of automated decision-making.

    (II) Voluntary PIA for Private Sector & General Government Projects

    • New/modified processes with high privacy risks to individuals;
    • Collection/use of large volumes of sensitive personal data (e.g., health, financial, biometric data);
    • Engagement of third-party data processors or cross-border transfer of personal data;
    • Implementation of large-scale data monitoring, AI analytics or customer marketing systems;
    • Revision of internal data privacy policies or personal data processing workflows.

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    How to Conduct PIA 私隱風險評估怎麼做 ?

    PCPD proposes a full set of guidelines in privacy assessment. Organizations including HKSARG Departments are required to adhere to PDPO and to conduct privacy assessment if information processing project has significant privacy implications.

    With the aim to identify the level of privacy impact of an existing operation or implementation, our PIA consists of the following components:

    • Data Processing Cycle Analysis
    • Privacy Risk Analysis
    • Risk Mitigation Recommendation
    • PIA Reporting

    📋 PIA Checklist

    We provide a dedicated checklist for evaluating data handling practices and identifying potential privacy risks through client self‑assessment.

    Please download the checklist here: PIA Info Request and DPPs

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    Our PIA Services 我們的私隱風險評估服務

    We offer Privacy Impact Assessment (PIA) as 3rd party independent assessor / auditor to fulfill PCPD requirements on PIA.

    Although methodology is standardized, scale & scope / target varies in different types of projects. The following catalogue lists out samples of our offerings:

    • Platform Design & Implementation specific
      • – Students / Patients / Hotel Residents management system
      • – Customer Information & Orders management system
      • – CRM system and Loyalty program
      • – CCTV surveillance monitoring system
      • – Portal / CMS based (e-Learning / e-Leave ) system

    • Application specific
      • – Web based Application
      • – Mobile App (Android or IOS, or both)
      • – Legacy Client / Server based
      • – IOT device

    • Network specific
      • – Public Cloud infra-structure (Azure, AWS, etc.)
      • – On-Premises External Network (Internet Facing)
      • – On-Premises Internal Network
      • – On-Premises Wi-Fi Network
      • – Hybrid Network including On-Premises Network & external IOT Device

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    Assessment Methodology 評估方法

    (1) Data processing cycle analysis

    identify and describe the handling of data processing cycles and information flows of the personal information in information system / process implementation / operation, covering aspects including –

    • Purpose and manner of collection;
    • Accuracy and duration of retention;
    • Use, disclose and transfer of personal data;
    • Security and safeguards of personal data to prevent unauthorized or accidental access, use, modification or loss of data;
    • Policy transparency to the access and correction of the personal data;
    • Access and correction; and
    • Destruction;

    (2) Privacy risks analysis
    • analyze the compliance level of assessed object, in terms of each aspect of the data processing cycles, with the personal data privacy requirements under the PDPO in detail, especially the DPPs under such Ordinance;
    • analyze and identify the potential privacy risks on each aspect of the data processing cycles involved in assessed object and the related work flow;
    • define the impact level and nature of each identified privacy risk;
    • identify any privacy standards and rules prescribed under applicable codes of practices, guidelines, policies and regulations that the data users shall observe;

    (3) Recommendations or measures in avoiding or mitigating privacy risks;
    • recommend safeguard measures based on the results of privacy impact analysis in order to reduce the likelihood of the identified issues and minimize the impact to an acceptable level;
    • recommend possible options and handling approaches in terms of administrative procedures and system functions to mitigate or eradicate the identified privacy risks, so that assessed object can fully comply with the PDPO;

    (4) Compiling PIA report
    • compile PIA report to document all findings, recommendations and improvement areas in detail;
    • conduct PIA presentations, discussion session, walk-through, review, etc. will be delivered on need basis;

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    Further Reading 延伸閱讀

    Personal Data (Privacy) Ordiance & 6 Data Protection Principles at a glance

    Personal Data (Privacy) Ordiance – an overview

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    1. The PCPD is an independent body set up to oversee the implementation of and compliance with the provisions of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (PDPO). The PCPD strives to ensure the protection of the privacy of individuals in relation to personal data through monitoring and supervising compliance with the PDPO, enforcing its provisions and promoting the culture of protecting and respecting personal data. More details about PCPD, please refer to PCPD Home Page ↩︎
    2. The Data Protection Principles (“DPPs” or “DPP”), which are contained in Schedule 1 to the Personal Data (Privacy) Ordinance (PDPO), outline how data users should collect, handle and use personal data, complemented by other provisions imposing further compliance requirements. ↩︎