EU Data Protection Certification System and China's Mirror
Achieving secure,orderly,and free cross-border data transfer is a significant policy issue for countries worldwide.Article 38 of the"Personal Information Protection Law of the People's Republic of China"explicitly stipulates a certification system for cross-border transfer of personal information.However,this system is still in its nascent stage and faces fundamental and implementation challenges,such as determining the objects of certification.The European Union,as the progenitor of data protection certification systems,offers a reference for the perfection of China's certification system through its institutional framework and distinctive features.This paper takes the EU's data protection certification system and China's personal information cross-border transfer certification system as its research subjects,compares with the differences in their institutional designs,and proposes five improvement suggestions,including clarifying the objects of certification,to address the systemic challenges in the construction of China's certification system.These suggestions aim to provide valuable support for the improvement and innovation of the personal information cross-border transfer certification system.
general data protection regulationdigital tradepersonal information protectioncross-border transmission of personal informationthird-party certification
万方数据
维普
