News & Analysis as of

China Personal Data

Morrison & Foerster LLP

China’s New CBDT Regime: One Year On

China rolled out its “new,” streamlined cross-border data transfer (CBDT) regime on March 22, 2024, with the issuance by the Cyberspace Administration of China (CAC) of the Provisions on Facilitating and Regulating...more

Baker Donelson

DOJ Final Rule Casts Wider Net: Common Business Data May Now Trigger National Security Scrutiny

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If you thought your company's collection of email address, IP address, zip code, birth date, or cookie data was too mundane to catch the federal government's attention – think again. Effective April 8, 2025, a new DOJ final...more

Dacheng

China Monthly Data Protection Update: May 2025

Dacheng on

This monthly report outlines key developments in China’s data protection sector for May. The following events merit special attention...more

Maynard Nexsen

Irish Data Protection Commission Fines TikTok Over EEA Data Transfers to China

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On May 2, 2025, the Irish Data Protection Commission (“DPC”) issued a decision, as lead supervisory authority, finding that TikTok infringed the GDPR regarding (a) its cross-border transfers of EEA User Data to China, and (b)...more

DLA Piper

China: CAC Publishes Official Q&As for Cross-Border Data Transfer Regulation

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The Cyberspace Administration of China (CAC) released an important Q&A on cross-border data transfer requirements and policies in early April, providing clarification on a number of issues of concern to companies in China....more

Womble Bond Dickinson

Navigating the New DOJ Data Security Program Compliance

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On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more

Dorsey & Whitney LLP

DOJ Limits Enforcement During First 90 Days of US-China Data Export Rules

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In a Press Release issued April 11, 2025, the U.S. Department of Justice (“DOJ”) indicated that it would prioritize “facilitating compliance” over civil enforcement actions for the first 90 days of its new US-China data...more

Goodwin

Life Sciences Companies Must Navigate the DOJ Data Rule

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Life sciences companies have long been outside the scope of US national security regulations and benefited from significant exemptions under US privacy laws. ...more

Ropes & Gray LLP

DOJ Releases FAQs and Compliance Guidance for Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and other...

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On April 11, 2025, the Department of Justice (“DOJ”) released additional detail regarding the Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal...more

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...more

Dacheng

A Practical Review of China's Restrictions on Cross-Border Transfer of Personal Information: Developments and Framework

Dacheng on

The cross-border transfer of personal information (hereinafter referred to as “PI,” and such transfers as “PI export”) is a routine and often essential part of business operations for companies in China—particularly...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

McDermott Will & Emery

Special Report - Navigating the DOJ’s Final Rule on Preventing Access to Bulk US Sensitive Data by Countries of Concern

The US Department of Justice’s (DOJ’s) Final Rule on preventing access to US sensitive personal data, published in the Federal Register on January 8, 2025, will prohibit or significantly restrict the transfer of or other...more

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

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On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

Proskauer Rose LLP

The DOJ’s Final Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered...

Proskauer Rose LLP on

On December 27, 2024, the Department of Justice (the “DOJ”) issued its final rule (the “Rule”) carrying out Executive Order 14117 “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

Troutman Pepper Locke

New DOJ National Security Division Data Security Rules Take Effect on April 8: Is Your Organization Exposed?

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Under the Department of Justice’s (DOJ) “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rules (the Rules), allowing access outside the United States...more

Cooley LLP

The DOJ’s Bulk Sensitive Personal Data Rule’s Imminent Relevance to Life Sciences Companies

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A new US Department of Justice (DOJ) rule on “Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern (including China) or Covered Persons” (rule) prohibits and restricts certain...more

Lathrop GPM

New DOJ Limits on Cross-Border Data Transfers Prompt Assessment by Businesses

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On April 8, the National Security Division of the U.S. Department of Justice’s (DOJ) new rule on cross-border data transfers takes effect. It restricts U.S. businesses from transferring certain bulk sensitive personal data to...more

DLA Piper

CHINA: Recent Enforcement Trends

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Recently, the Cyberspace Administration of China (CAC), which is the primary data regulator in China, published a newsletter about the government authorities’ enforcement of Apps and websites that violated personal data...more

A&O Shearman

PRC - New Measures for Personal Information Protection Compliance Audits

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The PRC Personal Information Protection Law (PIPL) mandates regular data compliance audits. Following a consultation period beginning in August 3, 2023, the Cyberspace Administration of China (CAC) issued the Measures for...more

Sheppard Mullin Richter & Hampton LLP

Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers Released for Public Comment

On January 3, 2025, the Cyberspace Administration of China (the “CAC”) released the Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers (the “Draft Measures”) for public comment....more

DLA Piper

CHINA: Mandatory Data Protection Compliance Audits from 1 May 2025

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Chinese data regulators are intensifying their focus on the data protection compliance audit obligations under the Personal Information Protection Law (“PIPL“), with the release of the Administrative Measures for Personal...more

Hogan Lovells

A Tale of Two CBDCs: e-CNY v. Digital Euro

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As global momentum appears to be building for the development of central bank digital currencies (CBDCs) – bringing with it the potential to disrupt and revolutionize global payments and finance - we have taken the...more

Snell & Wilmer

Supreme Court Upholds Law Restricting TikTok’s Operations in the U.S.

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On January 17, 2025, the Supreme Court issued its decision in TikTok Inc. v. Garland, affirming the constitutionality of the Protecting Americans from Foreign Adversary Controlled Applications Act (the Act), which restricts...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

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