Data Strategy Briefing — August 31, 2022

Executive briefing: On 31 August 2022 the Cyberspace Administration of China (CAC) issued the Guidelines for Application for Security Assessment for Outbound Data Transfers (First Edition) and standard forms that applicants must submit with the July 2022 measures. The package details documentation, attestations, and self-assessment content required from multinational organisations before sending important data or large volumes of personal information overseas.

Key localisation checkpoints

Document mapping. Assemble inventories, processing purposes, recipient profiles, and contractual safeguards aligned with Annex 1 of the guidelines.
Self-assessment scope. Ensure internal reviews cover legality, necessity, security capabilities, and foreign legal environments across all datasets implicated in a transfer.
Onshore storage. Confirm data residency strategies for important data that must remain inside China even when limited attributes are exported.

Operational priorities

Template adoption. Localise CAC forms A, B, and C for business units, ensuring translations, responsible signatories, and evidence repositories are in place.
Timeline governance. Create RACI matrices for the 60-day submission window granted to organisations whose transfers pre-date September 2022.
Remediation tracking. Build issue logs that capture CAC feedback, remediation actions, and re-assessment triggers to maintain continuous compliance.

Enablement moves

Embed outbound data assessment checkpoints into vendor procurement and product change control workflows.
Establish retention schedules and evidence archiving for all self-assessment materials in anticipation of CAC inspections.

Sources

Zeph Tech supports China data export governance with assessment toolkits, evidence collection frameworks, and bilingual submission support.