The implementation of the 2018 EU General Data Protection Regulations is regarded as a"model"for the protection of personal data rights under the"digital human rights"category,and its important reason is that its extraterritorial effectiveness meets the practical needs of cross-border data governance.Article 3 of the Regulation establishes an extraterritorial application framework for personal data protection through two dimensions of design:firstly,"workplace standards",if the data actions taken by entities controlling,processing,and using data outside the EU have an inseparable connection with the EU's domestic business premises,they must be regulated by the Regulation;Secondly,"target targeting standards",if the data actions carried out by o-verseas data controllers,processors,etc.are directed against data subjects within the EU,they are also subject to regulations.Although the two standards complement each other,the extraterritorial effectiveness of the regulations still faces a test.The expe-rience and test of extraterritorial effectiveness of regulations have also provided valuable experience and inspiration for China.
关键词
通用数据保护条例/域外效力/经营场所标准/目标指向标准/现实考验
Key words
General Data Protection Regulations/extraterritorial effects/business premises standards/target targeting standards/reality test