2026-03-26
Added · Updated
The HKMA provides guiding principles for authorized institutions regarding consumer protection when using alternative data in banking operations such as credit risk assessment. These principles require institutions to establish robust governance, ensure transparency and explicit prior consent, maintain data quality and fairness, and implement strict privacy safeguards. The document mandates annual compliance audits, clear communication with customers about data usage, and adherence to existing supervisory policy modules on credit data and AI.
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55th Floor, Two International Finance Centre, 香 港 中 環 金 融 街 8 號 國 際 金 融 中 心 2 期 55 樓 8 Finance Street, Central, Hong Kong 網 址:www.hkma.gov.hk Website: www.hkma.gov.hk Our Ref: B4/1C B9/32C B9/60C 26 March 2026 The Chief Executive All Authorized Institutions Dear Sir/Madam, Consumer Protection in the Use of Alternative Data I am writing to provide authorized institutions (“AIs”) with a set of guiding principles in respect of consumer protection in the use of alternative data in banking operations (such as credit risk assessment). Objectives The use of alternative data in banking operations (especially in credit risk assessment but also in customer onboarding and provision of various products and services in general) is increasingly prevalent. This is attributable to the rapid digitalisation and technological advancements which have expanded the availability of alternative data sources and computational power for data analytics. The distinction between traditional credit data and alternative data lies primarily in the source and type of information used to assess a borrower’s creditworthiness. In general, traditional credit data refers to credit and financial information focusing on borrowers’ debt history and repayment record, typically maintained by credit reference agencies (“CRAs”), which reflect borrowers’ ability and willingness to repay based on their historical credit activity. Alternative data, on the other hand, encompasses a vast range of non-traditional and often non-credit-related information sources that are not part of standard reports from CRAs. This type of data can reveal patterns, trends, or signals indicative of a borrower’s financial capacity that is typically not captured by traditional sources, including transactional
data (e.g. utility payment and e-commerce data), and non-transactional data (e.g. behavioural, social media and Web data). While traditional credit data remains a core component of credit risk assessment, CRAs and other data service providers are introducing alternative data products and solutions for credit providers in support of credit risk assessments, complementing the use of traditional credit data. This integrated approach in the use of traditional and alternative data provides more comprehensive information about the background and financial situations of customers and borrowers, enabling a more complete and real-time view of borrowers’ risk profiles and facilitating the evaluation of borrowers who may be excluded by traditional methods due to a lack of sufficient reliable traditional credit histories, thereby broadening the scope of credit risk assessment. Meanwhile, international standards and recommendations on the responsible use of alternative data in financial services are emerging and evolving. In drawing up the supervisory requirements and expectations, the Hong Kong Monetary Authority (“HKMA”) has made reference to international experiences and best practices, such as the World Bank report on “The Use of Alternative Data in Credit Risk Assessment: Opportunities, Risks, and Challenges” published in 2024. Guiding principles In general, and in line with pre-existing requirements as set out in Supervisory Policy Manual (“SPM”) modules IC-6 “The Sharing and Use of Consumer Credit Data through Credit Reference Agencies” and IC-7 “The Sharing and Use of Commercial Credit Data through a Commercial Credit Reference Agency”, AIs should have put in place clear and comprehensive policies and procedures governing the use of consumer and commercial credit data obtained from CRAs in managing credit risk. Such policies and procedures (including but not limited to management of service providers, access control, confidentiality and retention, compliance audit) should also apply to the use of alternative data by AIs in a technology- and source-neutral way. AIs should also enter into a formal contractual agreement with any alternative data provider(s) whose service they intend to engage, and require that data provider(s) to have effective control systems to ensure compliance with all the relevant legal and regulatory requirements. Recognising that alternative data is generally more diverse, less standardised or structured in nature, and considering the expanding availability of data sources, the HKMA has set out some additional guiding principles, with a view to supporting AIs’ ongoing innovation and enhancement of banking services to meet evolving customer needs, while strengthening consumer protection in the use of alternative data in the context of banking operations. These guiding principles on consumer
protection focus on four major areas, namely, governance and accountability, transparency and consent management, data quality and fairness, and data privacy and protection. AIs should adopt a risk-based approach commensurate with the evolving risks associated with the use of alternative data when applying these guiding principles.
(a) ensure the clarity and comprehensibility of consent mechanisms employed, enabling customers to make informed decisions about their alternative data; (b) obtain explicit prior consent from customers before collecting or using their alternative data, and clearly inform the customers about how their data is collected, processed, and used. In this connection, AIs that participate in Commercial Data Interchange (CDI) are encouraged to exchange the customer consent with the relevant alternative data provider through CDI where applicable; (c) collect only adequate and necessary data; (d) maintain a transparent audit trail; and (e) ensure implementation models are highly interpretable and decisions can be explained to the customers.
3. Data quality and fairness
AIs should establish clear protocols for suitable and proportionate data validation and evaluation to ensure the quality and fairness of alternative data, as well as the accuracy and fairness of the outcomes from credit risk assessment methods and processes1 . Accordingly, they should, among others:
(a) adopt reasonable procedures to ensure that credit risk assessment is carried out consistently using relevant, accurate, and adequate information about customers from reliable sources; (b) consider the variability in data quality, stability, accessibility, predictive power, nuances, and associated risks across different alternative data sources; and (c) test and monitor credit risk assessment models to prevent and correct unfair biases or disparate impacts. 1 This circular should be read in conjunction with any applicable guidance issued and updated by the HKMA from time to time, including the guidance on credit scoring system as set out in SPM module CR-S-5 “Credit Card Business” if AIs use alternative data in credit scoring for their credit card and unsecured consumer finance business. AIs should also refer to the circular “Credit Risk Management for Personal Lending Business” dated 27 October 2022 if alternative data is used in credit risk assessments for their New Personal-Lending Portfolio.
Conclusion
AIs are expected to review and, where necessary, enhance their current policies, procedures, and practices to align with the above guiding principles. The HKMA will monitor industry developments and provide further guidance as necessary to adapt to the evolving data ecosystem and environment. Should you have any questions regarding this circular, please contact us at credit_referencing_data@hkma.gov.hk. Yours faithfully, Alan Au Executive Director (Banking Conduct) cc: The Chairman, The Hong Kong Association of Banks The Chairman, The DTC Association Secretary for Financial Services and the Treasury (Attn: Mr Timothy Wong)
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Source: Hong Kong Monetary Authority — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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