Submitted Comments to the Ministry of Industry and Information Technology (MIIT) on the Guidelines for Identification of Key Data in Telecommunication Field

2024-04-12 | Beijing

On 12th April 2024, the European Chamber ICT working group and Cybersecurity sub-working group submitted comments to the Ministry of Industry and Information Technology (MIIT) on the Guidelines for Identification of Key Data in Telecommunication Field.

The working group advocated that Foreign-invested enterprises (FIEs) are important participants in the construction of China's digital economy. To do a good job in the development and construction of the digital economy, cross-border data flow cannot be ignored. During the past decades of economic construction, foreign-invested enterprises have generally deployed R&D resources, production facilities, sales networks and supply chains in China, and have accumulated a lot of practice in cross-border data flow. Due to their inherent transnational nature, FIEs inevitably involve cross-border data transfer. A broad and vague definition of the scope of important data will cause general business data to be expanded and thus included in important data management, which will unreasonably raise the compliance cost of enterprises.