跨境数据流动安全评估的整改机制

Rectification Mechanism for Security Assessment of Cross-Border Data Flow

摘要: 数字经济已深度融入经济社会各领域，数据跨境流动成为产业发展的重要支撑，但安全风险与合规挑战并存。我国已建立数据出境安全评估制度，为数据跨境流动提供合规保障，但实践中部分企业因整改机制操作指引模糊，面临问题描述笼统、修改方向不明、反复提交等低效困境，不仅增加企业合规成本，也制约了数据要素的自由流动。本文结合企业实操经验，借鉴澳大利亚相关制度实践，聚焦整改机制的优化路径，构建兼具针对性、可操作性与协同性的整改方案，以期平衡数据安全监管与数字经济发展需求，为数字时代高质量发展提供制度支撑。

Abstract: The digital economy has been deeply integrated into all sectors of the economy and society. Cross-border data flows have become an important pillar for industrial development, yet they are accompanied by concurrent security risks and compliance challenges. China has established a security assessment system for data outbound transfers, which provides compliance safeguards for cross-border data flows. However, in practice, due to the vague operational guidelines of the rectification mechanism, some enterprises are plagued by inefficient predicaments such as ambiguous problem descriptions, unclear revision directions and repeated submissions. These issues not only increase enterprises’ compliance costs, but also restrict the free flow of data as a key factor of production. Drawing on enterprises’ practical experience and relevant institutional practices in Australia, this paper focuses on the optimization paths of the rectification mechanism and constructs a targeted, operable and collaborative rectification scheme. It aims to balance the needs of data security supervision and digital economy development, so as to provide institutional support for high-quality development in the digital era.