Cross-border Data Flow Governance: The Integration of International Experience and China's Modernization Path

In the context of globalization and the rapid development of digital economy, data has become a new factor driving the development of productivity, and cross-border data flow has also become a key factor promoting international trade, investment and knowledge exchange. As two major data economies, the United States and the European Union have different legal frameworks and practice models in the management of cross-border data flows. The United States adopts a relatively decentralized and market-driven approach, regulated mainly through industry guidelines and federal and state laws. In contrast, the EU has formed a relatively unified legal system centered on personal privacy protection based on the General Data Protection Regulations (GDPR). This paper analyzes the cross-border data flow governance strategies of the United States and Europe to develop a suitable framework for China that incorporates international best practices while adapting to China's specific context. It suggests that China should learn from these advanced economies to create a flexible and effective data flow management system, ensuring a balance between data security and open communication. It also recommends enhancing China's data protection laws to align with its Civil Code and other legal systems, and advocates for China's participation in international efforts to establish global data governance standards. Ultimately, this paper outlines key considerations and strategic directions for China's future data governance strategy, offering insights and recommendations to support its modernization efforts.