Data Strategy Briefing — February 24, 2023

Executive briefing: The Cyberspace Administration of China (CAC) released the Measures on the Standard Contract for Outbound Transfer of Personal Information on 24 February 2023. Effective 1 June 2023, the measures define when companies can rely on CAC standard contracts instead of full security assessments, while still mandating filings within 10 working days and detailed transfer impact assessments.

Key localisation checkpoints

Eligibility analysis. Confirm that transfers fall below Article 4 volume thresholds (e.g., fewer than one million data subjects and fewer than 100,000 sensitive records processed since the previous year).
Impact assessments. Complete personal information protection impact assessments addressing processing purposes, transfer necessity, recipient safeguards, and foreign legal environments.
Contract tailoring. Incorporate the Annex standard clauses verbatim while adding supplemental provisions on audit rights, encryption controls, and data breach cooperation.

Operational priorities

Record-filing. Prepare filing packages for provincial CAC offices within 10 working days of signing, including the contract, impact assessment, and supporting evidence.
Lifecycle management. Track contract renewals and trigger new filings when transfer purposes, retention periods, or recipient profiles change materially.
System updates. Embed consent and notice requirements that mirror Annex 1 disclosures, ensuring data principals understand overseas processing.

Enablement moves

Develop bilingual contract playbooks and negotiation guidance for overseas affiliates receiving China-origin personal information.
Deploy monitoring dashboards that calculate cumulative transfer volumes to confirm eligibility and alert governance teams when approaching CAC thresholds.

Sources

Zeph Tech equips privacy and legal teams with CAC-standard contract templates, impact assessment toolkits, and record-filing governance workflows.