Data Strategy Briefing — November 12, 2021

Executive briefing: On 12 November 2021 APEC ministers responsible for the digital economy endorsed upgrades to the Cross-Border Privacy Rules (CBPR) System, charting a course toward a Global CBPR Forum and refreshed certification tools for privacy-compliant data flows across the Asia-Pacific.^{APEC press release}

Key governance checkpoints

Certification strategy. Evaluate current CBPR and Privacy Recognition for Processors (PRP) certifications and plan for expanded participation as the system transitions to a global forum.
Accountability measures. Refresh privacy management programmes to meet CBPR requirements on notice, purpose specification, security safeguards, access rights, and accountability.
Regulatory liaison. Engage accountability agents and supervisory authorities identified in the APEC programme to align audit evidence and complaint handling expectations.

Operational priorities

Gap remediation. Perform control assessments against CBPR and PRP program requirements, prioritising remediation for processor oversight, sub-processing approvals, and cross-border transparency.
Contract harmonisation. Incorporate CBPR data protection commitments into vendor agreements and intragroup data transfer contracts to accelerate certification renewals.
Monitoring cadence. Establish metrics for certification status, incident reporting, and regulator interactions as APEC finalises the Global CBPR Forum structure.

Enablement moves

Coordinate with privacy teams in Japan, Singapore, the United States, and other CBPR participants to share best practices on accountability agent engagements.
Develop stakeholder communications explaining how Global CBPR participation complements domestic privacy regimes such as LGPD, PDPB, and PDPA.
Prepare board updates that cover resource needs for certification expansion and opportunities for interoperable transfer mechanisms.

Sources

Zeph Tech advises Asia-Pacific programmes on CBPR certification roadmaps, accountability agent engagements, and interoperability with other global privacy frameworks.