Last review date: 2 January 2025

Arguably No.

Third country would refer to any country other than Vietnam.

Transfers of personal data to third countries are only permissible if there is a legal basis for the processing/transfer and one of the following applies:

☒  other solutions

Please see separate question for information on data localization provisions that are not restricted to personal data.

The overseas transfer of a Vietnamese citizen's personal data (i.e., data transfer across the Vietnamese border or offshore processing of personal data) is subject to the OTIA filing requirement; approval of the OTIA is nonetheless not a prerequisite for the transfer to take place (assuming that the personal data transferred is not classified as a State secret). Transferring personal data classified as a State secret will require the approval of competent State authorities. The authority responsible for granting the approval will depend on the level of the State secret (Top Secret, Secret, Confidential) and the specific area the data pertains to (e.g., politics, national defense, foreign affairs, economy, health & medication). Further, if personal data is classified as important data or core data pursuant to the Data Law, restrictions may apply for the cross-border transfer of such data.