Before the implementation of the HKIDR, when an RRI seeks clients’ consent for the transfer of their personal data to SEHK and the SFC, and when the RRI updates clients’ CID, it should reach out to all natural person Relevant Clients (in respect of obtaining consent) and all Relevant Clients (in respect of updating CID) respectively, regardless of whether these clients are active or dormant.
However, some flexibility is given to dormant clients who have not provided CID or consent (as appropriate) before the implementation of the HKIDR but wish to trade on the day when their accounts become re-activated (i.e. the day of entering into a trade, T day). A BCAN can be assigned by an RRI to the dormant client on the T day and the BCAN-CID Mapping File containing the dormant client’s updated CID can be submitted to SEHK’s data repository either before or after the order is submitted, but in any event before a cut-off time on T day prescribed by SEHK and set out in the HKEX Information Paper. For details of submission of the BCAN-CID Mapping File for dormant clients, please refer to paragraphs 126-130 of the Consultation Conclusions and paragraph 8 of the HKEX Information Paper.