BSA recommends rationalizing the Data Security Law with Vietnam's existing data governance framework, adopting a narrower and risk-based approach to data classification and cross-border data transfers, removing overlapping AI-related obligations, harmonizing incident reporting requirements with international best practices, and ensuring financial penalties are proportionate and based on revenue within Vietnam. BSA also urges Vietnam to extend the consultation process to allow for more comprehensive review of the draft's interaction with existing laws.

Translation: Vietnamese