Cross-border Data Transfer Lawyers in China

A cross-border transfer review starts with the actual data, systems, people, recipients, access paths, and business purpose. Only then can counsel test whether the flow includes personal information, sensitive personal information, or identified important data; whether an exemption applies; and whether security assessment, standard contract, certification, or another sector route is relevant.

Questions that change the route

What leaves mainland China?

Inventory fields, data subjects, sensitivity, volume, source systems, storage, onward transfers, remote access, and whether data has been identified as important.

Why and to whom is it provided?

Document the necessary business purpose, overseas recipient, processor roles, locations, retention, security controls, and return or deletion plan.

Which compliance path applies?

Test critical-information-infrastructure status, statutory thresholds, exemptions, free-trade-zone rules, sector requirements, impact assessment, consent, contract, certification, and filing needs.

Evidence to organize first

• System and data-flow diagram with field-level inventory
• Recipient, subprocessor, location, remote-access, retention, and deletion records
• Impact assessment, notices and consent analysis, transfer agreement, security controls, and volume calculations

Official orientation sources: Personal Information Protection Law overview · Provisions on Promoting and Regulating Cross-Border Data Flows · Network Data Security Management Regulation. Source check: 5 October 2026.