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2023 (1)

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Dissertation
Comparative analysis of cross border transfer of personal data regulatory frameworks in China, the United States and European Union

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Abstract

In recent years, the global data confrontation has entered a new stage. With the vigorous development of industries such as social media and the Internet of Things, the value of personal data is getting higher and higher, almost occupying a dominant position in digital transactions. The differences and underlying reasons for the implementation of Cross-Border Transfer of Personal Data regulation (CDPTR) between China, the United States and Europe are still unclear in the literature. In this study, the method of macro-comparison of laws is used to explain the differences, and on this basis, a functionalist model is built to study the reason of the large differences phenomenon in CDPTR between China, the United States and the European Union. The conclusion of the thesis is that functionalism still has a good effect in explaining the difference of CDPTR. National digital strategies are the main reason for the differences in CDPTR. Key words: Cross-Border Transfer of Personal Data regulation (CDPTR), digital sovereignty, General Data Protection Regulation (GDPR), The China Personal Information Protection Law (PIPL), California Privacy Protection Agency (CPPA), digital strategy

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