Shanghai streamlines outbound data transfer filing for multinationals
Shanghai has recorded its first outbound data transfer filing case since the city implemented its new negative list management measures for outbound data transfers at the end of April, with the inaugural filing completed in Jing'an district.
The first company to complete the filing under the new framework is ITX Asia Pacific Enterprise Management Co Ltd, the core operating entity in the Asia-Pacific market of Spanish retail giant Inditex, the parent company of ZARA. The company's daily operations involve substantial cross-border data exchanges, including cross-border order processing, customer communications, and supply chain coordination.
The measures extend the negative list's coverage from the pilot free trade zone to the entire city, streamlining compliance for foreign-invested enterprises engaged in global operations and for Shanghai-based companies conducting overseas business. As a result, eligible businesses can carry out cross-border data transfers more conveniently and at lower compliance costs.
With professional guidance and policy support from local authorities, ITX Asia Pacific submitted its filing based on operational needs, enabling more efficient cross-border business operations and centralized global management.
Previously, enterprises were required to complete the relevant filing, declaration or assessment procedures whenever they transferred important data overseas or exceeded specified thresholds for transferring personal information overseas.
Under the new measures, eligible enterprises may file a standard contract for the cross-border transfer of personal information or, where applicable, be exempt from the relevant compliance procedures.
