Is cross-border transfer of China's human genetic data an impossible mission?

Cross-border transfer of human genetic data is a crucial prerequisite for sharing such data globally. However, given the unique nature of human genetic data, this aspiration may not be easily realized. China, a country rich in biological resources, possesses a vast wealth of human genetic data. However, due to China's domestic laws and policies, human genetic data is considered both personal information, subject to regulations like the Personal Information Protection Law, and human genetic resources, governed by the Regulations on Management of Human Genetic Resources. This dual nature necessitates a double security review of human genetic data for cross-border transfer, rendering cross-border transfer of China's human genetic data a seemingly impossible mission. However, in recent years, China has refined its security review rules for cross-border data transfer to increase transparency and, in practice, has eased review criteria, issuing numerous administrative licenses. Such a shift of stance is not fortuitous but rather a planned and purposeful reflection of China's top-level design to promote self-reliance and self-improvement in science and technology, as well as its strategic goal of joining international digital economy organizations.