中国数据合规：外国投资者的路线图

Data Compliance inChina: A Roadmap forForeign Investors From Dezan Shira & Associates Navigating Trends in China’s DataCompliance RegimePg 04 Building a Future-Proof DataCompliance Framework Six Data Compliance Hotspotsfor 2025 and Beyond Introduction ADAM LIVERMOREPartnerDezan Shira & Associates In today’s digital economy, data has become a decisive resource – fuelinginnovation, enabling smarter decision-making, and shaping competitive advantage. As the value of data has grown, so too has the sophisticationof China’s regulatory approach. What began with the establishment ofcornerstone laws has evolved into a comprehensive compliance regimemarked by detailed implementation rules and increasingly consistent www.asiabriefing.com www.aseanbriefing.com www.china-briefing.com www.india-briefing.com For foreign-invested enterprises, the stakes are even higher. Data localizationrules, cross-border transfer restrictions, and evolving definitions of “personalinformation” and “important data” create unique challenges for businesses www.vietnam-briefing.com www.middleeastbriefing.com Yet these challenges also present opportunities. A well-structured, future-proofing data compliance framework not only reduces regulatory risk butcan enhance operational efficiency, build trust with regulators and partners, This issue ofChina Briefing Magazinetakes both a strategic and practicalperspective. We unpack the legal foundations, track recent legislative andenforcement trends, and provide actionable insights for building compliance Designed for business leaders, compliance officers, legal teams, and ITdecision-makers, we hope this publication equips you with the clarity and With kind regards, Credits Publisher- Asia BriefingMedia Ltd.Editor- Qian ZhouContributors- Tony Tangand Arendse Huld Adam Livermore Data Compliance in China:A Roadmap for Foreign Reference China Briefing and relatedtitles are produced by Asia BriefingLtd., a wholly owned subsidiaryof Dezan Shira Group. Content Contents Navigating Trends in China’s Data No liability may be acceptedfor any of the contents of thispublication. Readers are stronglyadvised to seek professional Pg 04 Building a Future-Proof DataCompliance Framework Pg 10 Six Data Compliance Hotspotsfor 2025 and Beyond For queries regarding the contentof this magazine, please contact: Pg 15 All materials and contents© 2025 Asia Briefing Ltd. Asia Briefing Ltd.Unit 507, 5/F,Chinachem Golden Plaza, 77Mody Road, Tsim Sha Tsui East Annual Subscription China Briefing Magazine is published fourtimes a year. To subscribe, please visitwww.asiabriefing.com/store. And please explore Follow Us Strategic Advisory and Commentaryinfo@dezshira.com Connect with us for the latest news,events and insights across Asia. Professional Serviceswww.dezshira.com/services LikeChina Briefingon Facebook Asiapediawww.dezshira.com/library FollowChina Briefingon Twitter Legal, Tax, Accounting Newswww.china-briefing.com/news Connect withDezan Shira& Associateson Linkedin ViewDezan Shira &Associateson Youtube Magazines, Guides, Reportswww.asiabriefing.com/store Podcast and Webinarwww.dezshira.com/library/search?type=podcast&language Scan the QR code to followus on WeChat and gainaccess to the latest investor Navigating Trends in China’s DataCompliance Regime Alongside China’s digital transformation, the country’s data compliance regulatory environment has matured rapidly,evolving from foundational legislation to strict and consistent enforcement. For foreign-invested enterprises operating Qian ZhouManager Tony TangManager, IT ServiceDezan Shira & AssociatesContributor In a landmark move that sent ripples across theinternational business community, Chinese mechanisms, and refining cross-border datatransfer rules– companies must move beyondreactive compliance and build systems that are regulators publicly penalized French luxury brandDior for unlawful cross-border data transfers –marking the first time a foreign company has In this chapter, we provide a structured overviewof China’s evolving data compliance landscape The September 2025 announcement followed adata breach earlier this year and revealed Dior’sfailure to obtain regulatory approval, inform users,or implement adequate security safeguards beforeexporting personal information to its headquarters Supporting regulations and guidelines China’s data governance framework has evolved rapidly beyond its three foundational laws – theCybersecurity Law(CSL),Data Security Law(DSL),andPersonal Information Protection Law(PIPL) –with a growing body of supporting regulations, This development underlines the urgency for foreign-invested enterprises (FIEs) to reassess their datagovernance strategies. As China continues to refine Despite the overall robustness, the pace and scope ofrulemaking have varied across regions and industries,resulting in a fragmented landscape. Acknowledging For example, the cross-border data transfer