Hong Kong edition
Where your financial data goes, stated plainly.
Real controls, honest status: what is in place today and what is still in progress.
Finbryn treats Hong Kong client financial data as sensitive by default. A written information security programme is in progress, and multi-factor authentication and least-privilege access are already in place. Data handling for our Pakistan-based team follows the data protection principles set out in Hong Kong's Personal Data (Privacy) Ordinance. Below is every control, with its real status.
How access and data are handled
Least-privilege access
Team members reach only the client systems and files their role requires, not a shared blanket login.
Device policy
Work on client files happens under a written device policy, not on personal, unmanaged machines.
Data handling under the PDPO
The Personal Data (Privacy) Ordinance sets six data protection principles covering lawful collection, accuracy, use limitation, security, openness and access rights. Our data processing agreement with the Pakistan team follows those principles for data handled on your behalf.
Cross-border transfer, stated honestly
The PDPO's specific cross-border transfer provision has not been brought into a separate mechanism the way the UK's IDTA or the EU's Standard Contractual Clauses have. We apply the ordinance's general principles to how data moves to our Pakistan-based team rather than claiming a mechanism that does not exist here.
Security
Controls and their current status
- In place6
- In progress7
- Planned3
Multi-factor authentication on client systems
Every team member connecting to a client's accounting software, bank feed, or shared storage does so behind multi-factor authentication. Single-factor password access to client systems is not permitted under our internal access policy, regardless of role or tenure.
Evidence: policy document
In placeLeast-privilege access control
Team members are granted access only to the specific client files and systems their engagement requires, not blanket access across the client base. Access is reviewed when an engagement ends or a role changes, and removed promptly rather than left open.
Evidence: policy document
In placeNo local storage of client files
Client accounting data is worked on inside the client's own software (QuickBooks Online, Xero, or similar) or an approved shared workspace, not downloaded and saved to an individual team member's laptop or personal device. This limits how many places a client's financial data can end up.
Evidence: policy document
In placeSigned non-disclosure agreement for every staff member
Every team member with any access to client financial information signs a non-disclosure agreement before their first day on an engagement, covering client data specifically, not just general company confidentiality. This is a condition of employment, not an optional add-on for larger accounts.
Evidence: policy document
In placeFull-disk encryption on team devices
Laptops used to access client accounting systems run full-disk encryption, so a lost or stolen device does not expose readable client data. This is a baseline device requirement before any team member is granted client system access, not a later hardening step.
Evidence: policy document
In placeDocumented onboarding and offboarding for client access
Every engagement follows a written checklist for granting access when a team member joins a client's books and revoking it when they leave the engagement or the company. This removes the common failure mode where a departed team member's access to a client's accounting software is simply forgotten.
Evidence: policy document
In placeWritten information security program (WISP)
A written information security program aligned to IRS Publication 4557, covering administrative, technical, and physical safeguards for taxpayer and client financial data, is being drafted ahead of handling any US tax preparation data. A summary will be published once it is adopted, and no US tax data will be processed before it is in place.
In progressData processing agreement templates with SCCs and IDTA
Standard Contractual Clauses for EU client data and a UK International Data Transfer Agreement, each paired with a transfer risk assessment, are being finalized with counsel to cover the cross-border transfer of client financial data from the UK and EU. These will be signed as part of onboarding for clients in those regions.
In progressSection 7216 consent workflow for US tax data
A written-consent workflow meeting the format required by Revenue Procedure 2013-14 is being built so that every US client explicitly consents, before any tax return information is disclosed, to that information being used and processed by our team. No US taxpayer data will be shared ahead of a signed consent.
In progressErrors and omissions insurance
A professional errors and omissions policy covering the firm's advisory and preparation-support work is in the process of being placed. We will not claim coverage is in force, or name a policy, until it is confirmed bound and the certificate is on file.
In progressCyber liability insurance
A cyber liability policy covering data breach response for client financial data is in the process of being placed alongside our errors and omissions coverage. As with that policy, we will not claim coverage exists until it is confirmed bound.
In progressThird-party software vendor review
A documented review of the security posture of every software vendor in our stack, QuickBooks Online, Xero, and connected apps, is being formalized into a standing checklist run before any new tool is adopted for client work, rather than left to individual judgment.
In progressWritten incident response plan
A documented, tested procedure for detecting, containing, and notifying clients of a security incident involving their data is being drafted alongside the written information security program. It will define notification timelines and responsibilities before it is relied on rather than after an incident occurs.
In progressSOC 2 Type I examination
We intend to engage an independent auditor for a SOC 2 Type I examination once the underlying controls above (WISP, incident response, vendor review, access management) are fully in place and operating, since a Type I report only has value once there is something real for the auditor to examine. No SOC 2 report exists today, and we will not use that language about ourselves until one is issued.
PlannedISO 27001 certification
ISO 27001 certification is a longer-term goal, particularly for UK and Australian clients where it carries more procurement weight, and would follow after SOC 2 readiness work is complete. No certification exists today and none is implied by any control listed above until it is actually issued.
PlannedIndependent penetration test
An independent, third-party penetration test of client-facing systems and internal tooling is planned as part of SOC 2 readiness work, to validate the access and encryption controls above rather than take them on faith. No test has been performed as of today, and none is claimed.
Planned
Questions
Questions about how data is handled
Does Finbryn hold a SOC 2 report?
No, not yet. A SOC 2 examination is planned. We will not claim SOC 2 status until a real report exists.
Where does our data physically go?
Into your own Xero, QuickBooks Online or Zoho Books file, accessed by our team under least-privilege permissions and a written device policy.
How is a Hong Kong cross-border transfer different from a UK or EU one?
The UK and EU require a named legal mechanism, such as the IDTA or Standard Contractual Clauses. The PDPO's own cross-border provision is not in the same position, so we follow its general data protection principles instead and say so on this page.
Do our books feed the auditor who signs our statutory audit?
Yes. Reconciled, access-controlled books are what your Hong Kong-registered auditor works from at fieldwork, which is one reason we keep access tightly scoped year round.
Who at Finbryn can actually see our financial data?
Only the accountants assigned to your file and the senior principal who reviews it, each with access limited to what their role needs, rather than a broad login shared across every team member on our side.
What happens to our data if we stop working with Finbryn?
You keep your Xero, QuickBooks Online or Zoho Books file, since it was always in your name, and any working papers or reports we prepared are handed over in full rather than held back after the engagement ends.
Next step
Ask us anything about how this works
If a control on this page needs more detail for your own review, book a call and we will walk through it.