Comments to TC260 on Guidelines for Data Cross-Border Transfer Security Assessment

2017-10-13 | Beijing

On 30th August, 2017, the National Information Security Standardisation Technical Committee (TC260) published the draft of Guidelines for Data Cross-Border Transfer Security Assessment for public consultation, in response to which the European Chamber submitted collated comments.

While acknowledging the Guidelines' efforts to further specify the procedure and methodology of the security assessment of cross-border transfer of personal information and important data, the European Chamber raised particular concern in the comments over the broad and vague coverage of "important data" and the unreasonable definition of "domestic operation", among other issues.