In conclusion, PIPL has a GDPR-like face but also a neoliberal heart. The resemblance to the GDPR is thus elusive and distracting insofar as it does not lead to harmonisation/interoperability, hence casting doubts on the existence of the Brussels Effect in China.

10/n

#BrusselsEffect #GravityAssist #GDPR #PIPL #dataprotection #privacy #China

enforcement priorities, thus making a case of 'asteroid capture'. Note that this is not a capture by GDPR-informed global standards, but China's own cyber-sovereignty ideology that is inherently at odds with European values in relation to data protection.

9/n

without looking at the details of enforcement. In the last part, prelim observations on future trajectories of PIPL are made based on its instrumental characteristics. We argue that the PIPL is so distinct from the GDPR in terms of institutional design, legal infra, and...

8/n

PIPL's alignment can be understood as a process of strategic acceleration i.e. China recognising the structural & instrumental importance of privacy legislation but intentionally leaving significant semantic gaps, rendering it almost impossible to gauge the real effects...

7/n

A further PIPL-GDPR textual comparison shows that the similarities are elusive, and claimed differences more contested than meets the eye. Despite being the most powerful form of gravity assist, the GDPR is still incapable of dictating China’s trajectory of DP development.

6/n

Gravity assist is needed in post-colonial societies because privacy/DP is neither culturally/political embedded nor legally institutionalised. We provide a historical analysis to show how China’s multiple trials to accommodate data protection across legal fields had failed.

5/n

Given the Brussels Effect hardly applies, we develop a supplementary theory 'gravity assist' to explain how China takes efforts to align, at least formulaically, with mainstream standards of data protection by managing cultural/political resistance, as well as literacy gaps.

4/n

In China’s specific case, neither concrete economic interdependencies nor shared values concerning privacy exist. The lack of de facto Brussels Effect in the initial years of GDPR enforcement re China further disincentivises sino-EU interoperability or harmonisation.

3/n

We provide a critical account of the Brussels Effect and its preceding theories in non-Western contexts where the culture of privacy is not entrenched and politics revolving around post-colonial stability, development and global competition.

2/n