Comparative Analysis of Cross-Border Data Flow Policies: EU, US, and China

In the digital age, cross-border data flows are a key driver of global economic growth. However, this growth is accompanied by mounting security and compliance risks. Although countries are prioritizing data security, the absence of unified, universally binding regulations creates a fragmented and complex governance landscape. This paper systematically reviews trade agreements, domestic laws, and international regulations to define the concept and scope of cross-border data flows. It also introduces a data lifecycle theory adapted for cross-border scenarios. Through a comparative analysis of relevant policies in the European Union, the United States, and China at various stages of the data lifecycle, the paper identifies commonalities and differences. Based on these findings, the paper provides policy recommendations to harmonize global data governance frameworks, strengthen international cooperation, and balance national security concerns with the free flow of data.