Libraly Journal

Libraly Journal ›› 2019, Vol. 38 ›› Issue (12): 92-97.

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The Comparative Analysis of Trans-border Data Flow Lawsand Regulations in European Union & U.S. and “ChineseWisdom” in Face of Challenge

Dong Fang    

  • Online:2019-12-15 Published:2019-12-20

Abstract: A relatively complete set of trans-border data flow laws and regulations have taken shape
in European Union and U.S., which is of great significance for global business activities and economic
growth. Using literature review and comparative analysis, the paper analyzes these laws and regulations, as
well as their main differences and similarities. The conclusions are as follows: the differences mainly exist
in patterns, legislative basis and value orientation; yet they both try to maintain the balance between the
trans-border data flow and economic interests. China should play to the full the “Chinese wisdom” so as to
actively greet the challenge of trans-border data flow.

Key words: Trans-border data flow, U.S.-EU Safe Harbor Framework, EU-U.S. Privacy Shield Framework, Data ownership, Social public interests