The Measures on the Standard Contract for Outbound Transfer
of Personal Information (the "Measures") promulgated
by the Cyberspace Administration of China (CAC) came into force on
1 June 2023. One day before, on 30 May 2023, the CAC issued the
Filing Guidance for the Standard Contract for Personal
Information Outbound Transfer (First Edition) (the
"Filing Guidance") with implementation guidance to the
Measures.
This Q&A deals with some of the more common questions raised
by small-scale data exporters based in China, including many
foreign-invested companies in the B2B segment, on the steps that
they need to take to remain compliant with PRC laws.
We will be using "outbound transfer" and
"export", as well as "data" and
"information" interchangeably in the following.