How to Send Data in Chinese Concept Share Audit Papers Abroad?
(By You Yunting) China and the US recently signed the Audit Supervision Cooperation Agreement, allowing supervisors and inspectors of the Public Company Accounting Oversight Board (PCAOB) to review audit materials of Chinese companies listed in the US in Hong Kong, including complete audit papers containing all information. According to media reports, Alibaba, JD and Yum China are the first businesses to be audited. Audit papers contain large amounts of data and personal information of domestic users (collectively “data”). I would like to discuss whether the audit paper review by the US parties is outbound data transfer and what procedures should be followed to transfer the data abroad according to Chinese laws.