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Hong Kong SAR · Private Sector

AI governance for Hong Kong enterprises.

Sentinel for Hong Kong — anchored on the PCPD's AI guidance (Aug 2021) and the Model Personal Data Protection Framework (June 2024).

The pressure

PCPD active, framework-led, Greater Bay Area context.

Hong Kong's Privacy Commissioner for Personal Data (PCPD) published AI guidance in Aug 2021 and the Model Personal Data Protection Framework in June 2024 — voluntary but treated as benchmark expectations. Enterprises operating across the Greater Bay Area need to bridge HK expectations with mainland China's binding regime.

Aug 2021
PCPD AI guidance published
Jun 2024
PCPD Model PDP Framework
GBA
Greater Bay Area context
TBC
Availability — register interest
Frameworks pre-loaded

Every framework Hong Kong cares about — encoded as data, cross-mapped on day one.

The Sentinel Framework Engine ships with these frameworks as machine-readable data, with explicit cross-maps. When you assess a use case, the workpaper, the review pack, and the auditor evidence trail are generated from this library — not authored from scratch.

PCPD AI Guidance

Guidance

Privacy Commissioner's voluntary AI guidance.

Effective: Aug 2021

PCPD Model Personal Data Protection Framework

Voluntary

Voluntary best-practice framework for personal data including AI use.

Effective: June 2024

Personal Data (Privacy) Ordinance (PDPO)

In force

Hong Kong's privacy ordinance.

HKMA Guidelines on AI use in financial services

Guidance

HKMA expectations for AI use by authorised institutions.

Plus universal AI standards (every jurisdiction)

ISO/IEC 42001:2023 — AI Management SystemNIST AI Risk Management Framework 1.0 (under federal review, 2026)OECD AI PrinciplesNational Framework for the Assurance of AI in Government (June 2024) — jointly endorsed by Commonwealth + all AU states/territories
Framework references are tracked actively but should be confirmed in detailed scoping for any live engagement.Last validated: 12 May 2026
Who Sentinel is for in Hong Kong

Built for international private sector.

DPO, CISO, or General Counsel at HK enterprises and multinationals with HK operations. Strongest fit for financial services and any organisation bridging HK / Greater Bay Area / mainland China compliance.

What ships, regardless of jurisdiction:

  • M1 · AI Use-Case Register
  • M2 · AIAF / equivalent Workpaper
  • M3 · AI Review Committee Workflow
  • M4 · Risk Register
  • M5 · Transparency Register
  • M6 · Regulatory Gap Tracker
  • M7 · Evidence Vault + Audit Log
  • M8 · Re-attestation Engine

What changes between jurisdictions is the Framework Library pack — the regulations, statutes, and guidance pre-loaded. The platform structure stays the same.

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Help shape Sentinel for Hong Kong Private Sector.

Tell us your jurisdiction-specific needs and we'll prioritise the framework pack accordingly. Registered organisations get founding-partner terms when their jurisdiction goes live.

Sentinel · Arrochar Consulting · sales@arrocharconsulting.com