Comments on the new CAC Data Transfer Q&A

Transfer of data across borders presents a particular compliance challenge for companies in China. Xiangxiang Ma, a partner of Anjie Broad Law Firm, analyses a new document which brings welcome practical clarification to this area

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China's cross-border data governance framework has undergone significant refinement in recent years. The newly released Data Transfer Q&A (the “Q&A”) issued by the Cyberspace Administration of China (“CAC”) provides crucial clarifications on China's evolving approach to balancing data security and the development of digital economy.

First, the Q&A clarifies that (i) regulatory requirements only apply to "important data" and “personal information”, and (ii) general data can flow freely across borders. This helps alleviate compliance burdens for businesses, enabling them to focus on maintaining necessary safeguards for important data and personal information categories.

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