In a new publication for Stanford University’s DigiChina Project, authors Samm Sacks, Krystal Chen Zeng and Graham Webster break down the regulatory framework and potential impacts of China’s 2024 overhaul of its cross-border data transfer regime. The authors unpack remaining questions and debates that will impact outbound data transfers from China, from what qualifies as national security data (“important data”) to volume thresholds triggering a mandatory government assessment, to regulatory burdens in free trade zones, and the concept of “necessity.”
The essay also offers a high-level overview of Chinese expert opinion on the matter and reminds readers that while they are able to provide a detailed snapshot of the current state-of-play for data transfers out of China, this policy area is likely to remain a moving target for quite some time.
To view the PDF version of this essay, please click here.
These statements are attributable only to the authors, and their publication here does not necessarily reflect the view of the Cross-Border Data Forum or any participating individuals or organizations.