Update –First Cases Of Security Assessment Approval For Outbound Data Transfers In China

On July 7, 2022, the Cybersecurity Administration of China ("CAC") issued the Measures for Security Assessment for Cross-Border Data Transfers (" Security Assessment Measures"), which took effect on September 1, 2022. The Security Assessment Measures provide that before engaging in any further cross-border data transfer activities, certain categories of data processors will need to pass a security assessment conducted by the Cybersecurity Administration of China . Many data processors are trying to get ahead of the requirements set forth by the Measures for Security Assessment for Cross-Border Data Transfers in order to ensure that their ordinary cross-border data transfers can continue without interruption. Having the first two examples of CAC security assessment approval serves as a positive sign that the process is being implemented and that companies are able to successfully pass the security assessments.