Introduction
On June 10, 2021, China officially passed China's first
Data Security Law, which will take effect on September 1,
2021. Following the introduction of the Data Security Law,
together with the Cybersecurity Law, which has been
implemented since June 1, 2017, and the Personal Information
Protection Law, which is undergoing public comment for its
second draft released on April 29, 2021, data compliance is
becoming increasingly important and complicated for companies
operating business in China or with data originating from
China.
Background
Before the enactment of the Cybersecurity Law in 2016,
China didn't have any dedicated national legislation on data
security, and the duty of protecting data was mainly left to
companies that collect and/or use data to implement voluntary
protection schemes. The 2016 Cybersecurity Law encompassed
the issue of cyber data management and security, but other types of
data remain unregulated. The Data Security Law fille
