The rapid development of Artificial Intelligence (AI) has generated much excitement over the past two years. Since the public launch of Open AI’s ChatGPT on 30 November 2022, generative AI and its capabilities have been at the forefront of the public consciousness, with AI making headlines on a daily basis.
However, the advancement and increased adoption of AI has also brought about unprecedented challenges for businesses and regulators, particularly in relation to personal data. A number of regulators in Asia have issued guidance on AI1, and on 11 June 2024, the Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD) joined them by issuing the “Artificial Intelligence: Model Personal Data Protection Framework” (Model Framework).2 The release of the Model Framework follows the PCPD’s previous Guidance Note titled “Guidance on the Ethical Development and Use of Artificial Intelligence” (Ethical AI Guidance Note) issued in August 2021;3 and the Office of the Government Chief Information Officer’s “Ethical Artificial Intelligence Framework”, first released in September 2022 and last updated in August 2023.4