China SCCs Recordal: Personal Data Cross-Border Compliance Clock Starts Ticking

In this article we discuss guidelines for the released SCCs recordal.

A regulatory update

On 30 May 2023, the Cyberspace Administration of China (CAC) issued the long-awaited Guidelines for Recordal of the Standard Contractual Clauses (SCCs) for Cross-border Transfer of Personal Information (the Guidelines), following the issue of the SCCs Regulations in March 2023.

With all these in place, the regulatory authorities are now officially ready to implement and accept applications for SCCs Recordal from 1 June 2023.

Key points

The Guidelines provide clarifications on various procedural issues and time limits relating to the SCCs Recordal. For example:

• The Personal Information Impact Assessment (PIA) reports should be completed within 3 months before submitting the applications;