Construction of a legal collaborative model for cross-border communication data flow in the Guangdong-Hong Kong-Macao Greater Bay Area

Guangdong-Hong Kong-Macao Greater Bay area is the core carrier of China's digital economy strategy. But the number of 5g base stations ranks first in the country. The construction of Hengqin international Internet data dedicated channel for three major telecom operators has been completed, and the cross-border flow of communication data is huge. The cross-border flow of communication data in the Guangdong-Hong Kong-Macao Greater Bay Area faces the dilemma of rule adaptation under the governance framework of "one country, two systems, and three legal domains". Due to limitations in the design of collaborative mechanisms between jurisdictions and the localization and adaptation of international rules, the current institutional mechanisms are difficult to break the value tension between data sovereignty and circulation efficiency. On the basis of deconstructing the systematic differences in legal basis, regulatory logic, and dispute resolution among the three regions, the resolution of cross-border communication data flow governance problems in the three regions should be based on the framework of "dynamic hierarchical governance+technical legal coordination", and the construction of a dynamic regulatory system based on the "negative list+whitelist" mechanism. A collaborative governance model covering legislative coordination mechanism to achieve security assessment and industry certification, as well as the establishment of a Greater Bay Area Data Governance Committee and a special arbitration mechanism, should be constructed. By combining scenario based verification methods, we aim to develop actionable implementation plans in areas such as cross-border communication services and infrastructure operations, achieving an effective balance between security supervision and data flow requirements. The rule of law collaborative model for crossborder communication data flow in the Guangdong-Hong Kong-Macao Greater Bay Area can promote the formation of a governance paradigm that balances national security, regional development, and individual rights protection, and facilitate the construction of a cross-border data governance system in the digital economy era.