ITIF submitted comments to the Chinese State Internet Information Office on a draft circular that covered requirements for the handling of personal and other important data. The draft “Circular of the State Internet Information Office on the Public Consultation on the Measures for the Assessment of Personal Information and Important Data Exit Security” would greatly expand the scope of local data residency requirements as well as measures that inhibit the seamless collection, use, and transfer of data. By increasing the cost and complexity of data management and cross-border transfers of data, the circular will undermine China’s ability to benefit from data-driven innovation. This draft circular, if implemented in its current form, will not only undermine Chinese firms’ own ability to use data to innovate, but also will discriminate against foreign technology firms who will be forced to set up or use duplicative computing facilities and be constrained in how they use data.
