DOJ’s Bulk Sensitive Personal Data Rule: Life Sciences Compliance, Global Relay Intelligence & Practice

Partners Todd Liao, David Plotinsky, and Carl Valenstein co-authored an article for Global Relay Intelligence & Practice about the US Department of Justice’s Data Security Program (DSP) and its implications for cross-border data flows in the life sciences industry.

The authors highlight key compliance considerations for US pharmaceutical companies and Chinese biotechnology companies navigating the DSP, including restrictions on genomic and other sensitive personal data and the narrow scope of the clinical investigation exemption. They also address how potentially conflicting US and Chinese data requirements can affect the structuring of cross-border research collaborations, licensing arrangements, and other transactions, making data governance and DSP readiness increasingly important considerations in life sciences partnerships.