CAC Publishes Guidelines on Declaration for Security Assessment of Overseas Transfer of Data

Summary

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• The CAC has published guidelines for data handlers in relation to completing the risk self- assessment required under PRC law
• The Guidelines contain considerable detail on the declaration assessment procedure
• There are a number of template documents included within the Guidelines
• The Guidelines set out further procedural requirements

The night before the Measures for the Security Assessment of Overseas Transfer of Data (the Measures)(数据出境安全评估办法) became effective, the Cyberspace Administration of China (CAC) published the Guidelines for Filing for Security Assessments of Overseas Transfers of Data (First Edition) (the Guidelines) (数据出境安全评估申报指南(第一版)). The Guidelines aim to provide guidance and assistance for data handlers in completing the risk self-assessment and preparing the relevant declaration documents.

In CAC's official Q&A released together with the Measures in July, CAC clarified for the first time the issue of what constitutes "cross-border data transfers"