CHINA SYSTEM · OPERATING LOGIC
Read the concept through its operating structure
First identify the transfer and data type
Transfers to overseas headquarters, cloud or partners—and overseas remote access—may be outbound data activity. Classify personal, sensitive, important, core and ordinary business data first.
Security assessment covers important data and large-scale transfers
Security assessment applies to important data and transfers over volume thresholds, examining purpose, scope, recipient, contracts, safeguards and national and individual risk.
Standard contracts and certification are distinct routes
Standard contract and personal-information certification are different routes; neither replaces notice, consent, necessity, impact assessment, rights and incident response, nor can they bypass required security assessment.
The 2024 rules and FTZs simplify some transfers
The 2024 rules simplify certain trade, transport, academic, global production, HR and small-volume transfers. FTZ negative lists can exempt listed procedures outside the list, while core/important data and other laws remain.
Korean firms should map data flows before contracting
Korean firms should map China-origin customer, employee and equipment data through servers, APIs and remote access to Korea and third countries, then verify onward transfer, retention, deletion, government requests, incidents and controls.