- Purpose / Background:This circular provides authorized institutions (AIs) with guiding principles for consumer protection when using alternative data in banking operations, particularly for credit risk assessment. It addresses the increasing prevalence of alternative data due to digitalization and technological advancements.
- One-line conclusion (what changed / what needs to be done):AIs must review and enhance their policies and procedures to align with new guiding principles for consumer protection in the use of alternative data, covering governance, transparency, data quality, and privacy.
- Key Changes (3-8 bullets):
- Introduction of four key guiding principles for consumer protection: Governance and Accountability, Transparency and Consent Management, Data Quality and Fairness, and Data Privacy and Protection.
- Enhanced emphasis on board and senior management responsibility for oversight of alternative data usage.
- Requirement for clear, comprehensible consent mechanisms and explicit prior consent for collecting and using alternative data.
- Protocols for ensuring data quality, accuracy, and fairness of outcomes from alternative data-driven assessments.
- Implementation of safeguards for data privacy and protection, ensuring compliance with the Personal Data (Privacy) Ordinance.
- Continued reference to existing policies for credit data sharing and use, applying them to alternative data in a technology-neutral manner.
- Key Dates / Deadlines:Not explicitly stated for immediate action, but AIs are expected to review and enhance policies "where necessary." The HKMA will monitor developments and provide further guidance.
- Applicability / Impact scope:All Authorized Institutions (AIs) using alternative data in their banking operations, including credit risk assessment, customer onboarding, and provision of products and services.
- Recommended management actions (3-7 actionable bullets):
- Conduct a thorough review of current policies and procedures related to alternative data usage against the four guiding principles.
- Ensure board and senior management actively approve and oversee alternative data strategies and policies.
- Update consent mechanisms to be clearer, more comprehensible, and ensure explicit prior consent is obtained.
- Implement robust data validation and testing procedures to ensure the quality, accuracy, and fairness of alternative data and associated outcomes.
- Strengthen data security and privacy safeguards, confirming compliance with the Personal Data (Privacy) Ordinance.
- Provide regular training to staff on ethical and privacy requirements for handling alternative data.
- Establish clear processes for due diligence on data sources and third-party providers.
- Document overview (nature, purpose, scope)This circular, dated 26 March 2026, provides authorized institutions (AIs) with guiding principles for consumer protection in the use of alternative data within their banking operations. The purpose is to address the increasing use of diverse, non-traditional data sources in areas like credit risk assessment and customer onboarding, ensuring consumer protection keeps pace with technological advancements. It complements existing requirements for traditional credit data.
- Main requirements (group by topic; state what must be done)AIs are expected to apply existing policies for consumer and commercial credit data to alternative data in a technology- and source-neutral manner. Furthermore, they must implement formal contractual agreements with alternative data providers. The circular outlines four key areas for consumer protection when using alternative data:
- Governance and Accountability: Board and senior management are accountable for approving and overseeing policies, procedures, and alternative data-driven decisions. This includes clearly defining objectives, roles, responsibilities, permissible data sources, establishing robust data policies for consent, validation, collection, processing, correction, and storage, implementing due diligence for data sources and providers, continuous monitoring for data biases and errors, conducting annual compliance audits, and providing staff training.
- Transparency and Consent Management: AIs must ensure clear communication with customers about data types, implementation methods, limitations, and impacts, emphasizing informed consent. This involves clear and comprehensible consent mechanisms, obtaining explicit prior consent before data collection/use, clearly informing customers how data is processed, collecting only adequate and necessary data, maintaining a transparent audit trail, and ensuring implementation models are interpretable and decisions can be explained.
- Data Quality and Fairness: AIs need clear protocols for data validation and evaluation to ensure the quality and fairness of alternative data and outcomes. This includes adopting reasonable procedures for consistent credit risk assessment using relevant, accurate, and adequate information from reliable sources, considering variability in data quality across sources, and testing/monitoring models to prevent unfair biases or disparate impacts.
- Data Privacy and Protection: AIs must implement necessary safeguards for privacy and cyber risks. This involves complying with the Personal Data (Privacy) Ordinance (Cap. 486), adopting reasonable procedures for safeguarding data (security, confidentiality, proper utilization), and guarding against unauthorized access or use of sensitive customer information.
- Key changes (vs previous requirements)This circular introduces specific guiding principles focused on alternative data, building upon existing requirements for traditional credit data. Key changes include a more structured approach to governance and accountability for alternative data, explicit requirements for transparent consent management and informed consent for alternative data collection and use, specific protocols for ensuring the quality and fairness of alternative data and its derived outcomes, and heightened emphasis on safeguards for data privacy and protection due to the nature of alternative data. It also acknowledges the intersection with AI and machine learning, referencing prior HKMA guidance.
- Important dates & transitionThe circular does not specify a particular effective date or a transition period. It states that AIs are expected to review and, where necessary, enhance their current policies, procedures, and practices to align with the guiding principles. The HKMA will monitor developments and provide further guidance as needed.
- Impact and risks (operations/compliance/IT/data/reporting)
- Operations: AIs may need to invest in new systems or modify existing ones to manage alternative data, ensure consent, and maintain audit trails. Staff training will be crucial. Processes for data validation, quality assessment, and bias detection may require enhancement.
- Compliance: Significant focus on ensuring compliance with the Personal Data (Privacy) Ordinance and the new guiding principles. This includes rigorous consent management, data protection, and audit processes. Failure to comply could lead to regulatory action.
- IT/Data: The use of diverse alternative data sources may increase data complexity and require advanced data management and analytics capabilities. Robust data security measures are paramount to prevent breaches.
- Reporting: While not explicitly stated, AIs may need to adapt internal reporting to demonstrate compliance with the new principles, particularly regarding governance, consent, data quality, and privacy.
- Compliance action checklist (practical steps)
- Policy Review: Conduct a comprehensive review of existing policies and procedures related to credit risk assessment, customer data handling, and third-party data usage.
- Principle Alignment: Explicitly align these policies with the four guiding principles: Governance and Accountability, Transparency and Consent Management, Data Quality and Fairness, and Data Privacy and Protection.
- Governance & Oversight: Ensure board and senior management have clear oversight and accountability frameworks for alternative data use.
- Due Diligence: Establish or enhance a thorough due diligence framework for selecting and verifying alternative data sources and third-party providers.
- Consent Mechanisms: Develop or refine consent mechanisms to be clear, comprehensible, and ensure explicit prior consent is obtained for alternative data collection and use.
- Data Quality & Fairness Protocols: Implement robust procedures for validating alternative data, assessing its quality, and testing credit risk models to mitigate biases.
- Privacy & Security Safeguards: Strengthen data security protocols and privacy measures, ensuring full compliance with the Personal Data (Privacy) Ordinance.
- Staff Training: Develop and deliver comprehensive training programs for all relevant staff on ethical considerations, privacy requirements, and procedures for handling alternative data.
- Audit Trails: Ensure the maintenance of transparent audit trails for data collection, processing, and decision-making.
- Contractual Agreements: Review and update contracts with alternative data providers to include requirements for effective control systems and compliance with legal and regulatory obligations.
- Appendices/attachments summary (if any; 1-3 sentences each; total <= 20%)This document does not contain specific appendices or attachments. It references existing HKMA circulars and guidance documents, including Supervisory Policy Manual (SPM) modules IC-6 and IC-7, and other circulars related to credit risk management and customer data protection, which are to be read in conjunction with this circular.