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Cross-Border Data Compliance Guide

Let Skills Go Global Securely & Compliantly

Cross-border Skill delivery inevitably involves data export. This guide helps members judge the compliance path, prepare filing materials and control legal risk under the Hainan Free Trade Port cross-border data policy framework.

I. Three Basic Judgment Lines

Does data leave the border? Providing data to overseas parties, allowing overseas access, or cross-border remote calls may all constitute export.
Is it on the negative list? Listed data requires filing, assessment or certification per regulations; off-list data may use facilitation measures.
Does it involve personal information or important data? Personal information requires separate consent and corresponding obligations; important data requires a risk assessment.

II. Four Common Compliance Paths

Path	Applicable Scenario	Key Points
Off-List Facilitation	General business data, non-personal information	Handle under FTP facilitation measures; keep ledgers and traces
Standard Contract	Personal information export below a threshold	Sign a standard contract and file it; conduct a personal-information protection impact assessment
Protection Certification	Intra-group cross-border, repeated continuous transfer	Obtain professional personal-information protection certification
Security Assessment	Important data, or personal information above the threshold	File a data-export security assessment with the authority

III. Technical Compliance for Cross-Border Skill Delivery

Data classification & grading: a Skill description file must declare the data types and sensitivity levels it processes.
Minimization: transmit only fields necessary for the function; keep localizable data onshore.
De-identification & encryption: de-identify before export; encrypt in transit and at rest.
Auditable: retain complete call logs and data-flow records for traceability.
Controllable cutoff: possess the technical ability to emergency-stop cross-border transfer.

IV. Services the Association Provides

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Compliance Path Diagnosis

Judge the applicable path from your business scenario; output a compliance plan recommendation.

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Filing Material Guidance

Assist in preparing assessment filings, standard-contract filings and impact assessments.

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Cross-Border Data Space Access

Connect to DEPA rules and cross-border data-space construction; explore mutual-recognition mechanisms.

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Important Notice

This guide is general information, not legal advice. Compliance judgments for specific projects follow the requirements of the competent authority; professional legal counsel is recommended. The Association's Cross-Border Data Compliance Committee offers members preliminary consultation: info@hnaia.org