The Shanghai Whitelist Pilot for Data Transfers

June 12, 2024 | BY

Susan Mok

Philip Qu and Qiuchen Wang from TransAsia Lawyers analyze a pioneering approach to regulating cross-border data transfers recently adopted in one of Shanghai's free trade zones

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Summary

  • The cross-border transfer of data is a key issue for many companies operating in China, with many facing a significant compliance burden as a result of complex regulatory requirements
  • Regional deregulation is being trialed in the Lingang Special Area in Shanghai, based on whitelists with a scenario-based approach
  • The whitelist applies only to three specific sectors (biomedicine, intelligent connected vehicles, and mutual funds) although this will impact a number of international companies
  • The trial may set a precedent for other sectors