Data Localization Goes Global?
Sep 18, 2017

Morrison & Foerster

Morrison & Foerster Client Alert

Data Localization Goes Global?
China’s TC260 seeks to push the territorial scope of the Cyber Security Law

Marketing Department
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105

Late last month, the National Information Security Standardization Technical Committee of China (also known as “TC260”) released a number of draft CSL-related guidelines and standards. Among them was a second draft of Information Security Technology – Guidelines for Data Cross-Border Transfer Security Assessment (信息安全技术 数据出境安全评估指南(征求意见稿); the “Export Guidelines”). The Export Guidelines include a provision suggesting that data localization requirements under the CSL and draft implementing rules should be interpreted to apply to overseas companies that provide products and services “to” China, even if they do not have computer infrastructure or any business registration in China.

Read our client alert.


©2017 Morrison & Foerster LLP |