Shanghai, Sept. 17 (Xinhua) — The China (Shanghai) Pilot Free Trade Zone (hereinafter referred to as the Shanghai FTZ) has seen tangible results in exploring a negative list for data出境 (data /transfer abroad).
It was learned from the FTZ Data Outbound Negative List Practice Exchange Event and the launch ceremony of the 2025 National Cybersecurity Publicity Week Pudong New Area activities on the 17th that since the announcement of the “China (Shanghai) Pilot Free Trade Zone and Lingang Special Area Data Outbound Management List (Negative List) (2024 Edition)” (hereinafter referred to as the “Negative List”) on February 8, Pudong New Area has formed four use cases of the negative list in the reinsurance and pharmaceutical fields, effectively reducing the compliance costs for enterprises’ data出境 under the premise of controllable risks.
Cross-border data flow is gradually surpassing trade and investment globalization to become a new driver of global economic growth. Pilot free trade zones in Beijing, Shanghai, Hainan, and other places are exploring cross-border data flow, releasing the value of data elements through institutional innovation. The Shanghai FTZ’s “first move” for 2025 reform and innovation has been made in the field of facilitating cross-border data flow.
As a multinational pharmaceutical company registered in the FTZ, Ren Minmin, Chief Data Compliance Officer for Greater China at Boehringer Ingelheim, stated in an interview that the company often involves extensive跨国协作 (cross-national collaboration) and data sharing in areas like drug research and development and pharmacovigilance, making an efficient, stable, and predictable cross-border data circulation mechanism very important.
“With the ‘Negative List’, data not on the list can be exempted from data compliance declarations and filings. For enterprises, this can greatly enhance the convenience and efficiency of data出境, and also provides an efficient, clear, and low-cost path for data出境 and regulations,” said Ren Minmin. For example, she noted that the assessment threshold for sensitive information in pharmacovigilance scenarios was previously 10,000 people but has now been raised to 100,000 people. “This not only reduces compliance costs but also allows us to focus more energy on new drug研发 (R&D), bringing good medicines to patients faster.”
Meanwhile, against the backdrop of many FTZs in China constructing negative lists for data出境, Shanghai has taken the lead in explicitly allowing the use of negative lists from all national FTZs. “We are registered in Pudong but can also enjoy policy benefits from other regions. This approach of ‘breaking down barriers’ makes us more confident in investing in Shanghai,” said Ren Minmin.
Behind the bold exploration and practice of Shanghai FTZ enterprises lies the support and guidance of professional forces.
After the announcement of the “Negative List”, data cross-border service centers were officially established in the five major areas of the Shanghai FTZ: the保税区 (Bonded Zone), Lujiazui, Jinqiao, Zhangjiang, and世博 (Expo). From February 13 to now, nearly 20 policy briefings and application guidance activities have been conducted, with one-on-one接待解答 (reception and answering) for 74 enterprise consultations, serving over 1,000 enterprise visits in the jurisdiction.
Given that the field of data出境安全管理 is new, involves a wide range of industries, and is highly professional, Pudong New Area has established an expert group for data cross-border facilitation service reform and selected a number of technical service support units for network data security to help enterprises expand into overseas markets.
The expert team continues to “expand”. During the event, the second batch of expert representatives from the Shanghai Information Security测评认证中心 (Evaluation and Certification Center), Shanghai Data Exchange, China Telecom Shanghai Company, Shufeng Technology Co., Ltd., and other units received letters of appointment, and 6 professional institutions received certificates as technical service support units for network data security. (End)