China's Initial Draft Regulations On The Management Of Online Data Security: Important Takeaways

On November 14, 2021, the Cyberspace Administration of China (CAC) released draft Regulations on the Management of Online Data Security (the "Regulations") for China's data privacy and security laws, including the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL). Consistent with such laws, the Regulations broadly apply to processing activities of individuals and organizations within China and outside of China. The Regulations contain many similar principles to those set forth in other comprehensive data privacy and security laws, such as the EU's General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), however, there are material differences that, if published, would reshape privacy and security compliance for many businesses.