关键词: 数据跨境流动, 数字经济, 数据治理, 数据安全, 数据主权

Abstract: The development of the digital economy has made crossborder data flow an inevitable trend, and while bringing economic benefits, the security of crossborder data flow cannot be ignored. Due to the complexity of the subjects and scenes involved in the process of crossborder data flow, and the uncontrollability of the process, how to regulate the possible security problems in the process of crossborder data flow has become the focus of the world. So far, there is no unified governance rule system for crossborder data flow in the world, and at the same time, there are huge differences in legislation on crossborder data flow in different countries, which results in the complex situation of legislation on crossborder data flow in the world. This paper describes the current situation of crossborder data flow from the perspectives of laws and regulations, bilateral agreements and standards, and in this way develops horizontal comparisons, sorts out the existing regulatory differences, analyzes the challenges and opportunities China faces under the current trend, and gives reasonable countermeasures.

Key words: crossborder data flow, digital economy, data governance, data security, data sovereignty