New measures for Data Security Management

China continues to regulate data security. The Data Security Management Measures in the Field of Industry and Information Technology, which took effect on January 1, 2023, further specify the management of the entire life cycle of data. Companies should primarily pay attention to the following four requirements: 

Data localization: It is not explicitly required that important data and core data must be stored in the Chinese territory. However, they must be stored there if laws and administrative regulations require them to be stored in the national territory.

Cross-border data transfer: The transfer of data stored on Chinese territory to foreign authorities in the fields of industry, telecommunications and radio monitoring must be approved by the Ministry of Industry and Information Technology. A security assessment must be conducted for important data and core data collected and generated on Chinese territory.

Security risk assessment: With regard to the provision, transfer and contract processing of core data, data controllers shall assess the security risks, take necessary security measures and report to the Ministry of Industry and Information Technology for review after an initial review by the industry supervision department in the region.

Retention of data processing logs: Logs of data processing, authorization management, and personnel transactions must be maintained and retained for at least six months.

If data processing activities pose a relatively high security risk, they will be audited by the trade supervisory authority. The latter then implements measures to eliminate risks. In cases where there is simultaneous processing of data at different levels and it is difficult to implement separate protection measures, the highest level of protection must be implemented.


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