How the GBA Standard Contract eases personal-data flow from the mainland to Hong Kong — and why it does not change Hong Kong’s own outbound regime.

dgm is an independent osFoundry integration partner — not affiliated with osFoundry’s maker (OS LLC), and dgm has no completed client integrations yet.

For Hong Kong firms working across the boundary, moving personal data between the mainland and Hong Kong is governed by separate regimes. The Greater Bay Area Standard Contract is the facilitation route — within limits.

What the GBA Standard Contract is

The Standard Contract for the Cross-boundary Flow of Personal Information within the Greater Bay Area is a facilitation measure announced in December 2023 and extended to all sectors from 1 November 2024. It lets parties sign a standard contract instead of going through the mainland’s general export requirements for in-scope transfers, covering Hong Kong and nine mainland GBA cities.

What it does and does not change

It primarily eases the mainland-to-Hong-Kong (and within-GBA) export under mainland PIPL rules. It does not change Hong Kong’s own outbound regime, which remains unrestricted because PDPO section 33 is not in force. Do not treat it as a Hong Kong export restriction.

What it means for AI

If your AI pipeline pulls personal data from the mainland into Hong Kong, the mainland PIPL regime applies on that leg, and the GBA Standard Contract is the relevant facilitation route. Data processed purely in Hong Kong falls under the PDPO. osFoundry’s managed cloud pins data to the US, EU or Japan — it does not currently offer a Hong Kong managed region (its nearest managed region is Japan). To keep data in Hong Kong, the honest path is self-hosting osFoundry (BYO Cloud) inside a Hong Kong cloud region such as AWS Asia Pacific (Hong Kong) ap-east-1, Microsoft Azure East Asia (Hong Kong SAR) or Google Cloud asia-east2 (Hong Kong), or running models locally on-device.

Where dgm fits

dgm is an independent integration partner that helps Hong Kong businesses adopt osFoundry — scoping a first use case, handling the build, and connecting AI to the systems you already run. dgm is independent of osFoundry’s maker (OS LLC) and has no completed client integrations yet, so everything described here is a service offered, not a past result. If you want to scope a practical first project, dgm can help you map it out.