BEIJING, SINGAPORE – December 1, 2021 – The Global Data Alliance joined 27 associations across six continents in support of a joint letter relating to a proposal by the Cyberspace Administration of China (CAC) that would impose requirements for advance review and approval of various types of data transfers out of China.

“The multiple and overlapping security assessment and approval requirements proposed here should be approached with caution,” said Eunice Lim, Senior Manager – Policy at BSA | The Software Alliance. “The risk of unintended consequences is not small. It’s really critical to build in ample opportunity for consultation with affected stakeholders and to ensure that these types of measures help – not hurt – government objectives.”

The global industry letter urges the CAC to ensure that its proposed measures afford equal treatment to Chinese and foreign enterprises, services, and technologies, and that those measures be administered in a uniform, impartial, and reasonable manner with a view to ensuring non-discriminatory and streamlined approvals. The letter also urges Chinese authorities to assess carefully whether these requirements are in fact necessary to achieve China’s public policy objectives; to assess less restrictive alternatives; and to assess the broader economic and non-economic costs of such measures, as set forth in the GDA’s Cross-Border Data Policy Principles.

Today’s letter follows two related global industry letters submitted in November 2020 and June 2021. The ability to transfer data securely across transnational digital networks is of central importance to the national policy objectives of many countries, including China.

Data transfers support COVID-19 response and recovery, economic development, digital connectivity, cybersecurity, fraud prevention, anti-money laundering, and other activities relating to the protection of health, privacy, security, and regulatory compliance. Data transfers also support global supply chains, innovation, productivity, and environmental responsibility in every sector of the economy. 75 percent of the value of data transfers accrues to industries like agriculture, logistics and manufacturing.