New Heights in Data Protection: What Companies Need to Know About China's Data Security Law

July 04, 2021 | BY

Susan Mok

Rongwei (Ron) Cai, Jianwei (Jerry) Fang, and Dianmeng Zhu of Zhong Lun Law Firm introduce the newly enacted PRC Data Security Law, highlight the core data security protection obligations imposed on companies, and set out steps companies should be taking immediately in order to ensure compliance

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Summary:

 

  • Some clauses in the DSL have extraterritorial effect and therefore apply to foreign companies.
  • Processors of "important data" will face strict regulatory requirements.
  • Multinational companies may face a legal compliance dilemma when there is a conflict between the rules in China and a foreign jurisdiction.
  • Given that the DSL will take effect on Sept. 1, 2021, multinational companies should immediately take proactive actions to self-review and self-assess their data processing activities. 
  • We anticipate implementing rules and industry standards to supplement the DSL.