Your commentary does not make it clear that there is an appeal procedure through the Film Censorship Board of Review, the Chairman and majority of members of which are independent of the Administration. The Board is also required to take Article 19 of the ICCPR into account.
fm
I hope you find these comments helpful. We share your concern that the freedom of expression and information should be properly safeguarded in Hong Kong as elsewhere, both now and in the future: and we are working to that
end.
Yours Sincerely
Alan Pawl
A R Paul
Hong Kong Department