Viet Nam’s landscape of data governance is a collage of legal instruments variously reflected in the country’s constitution, criminal code, civil code, and a raft of sectoral and procedural regulations.

Taken together, the Ministry of Public Security’s (MPS) much-anticipated Draft Decree on Personal Data Protection (“draft PDPD”) and the Draft Decree on Sanctions against Administrative Violations in Cybersecurity (“draft cybersecurity decree”) constitute the government’s ambitious effort at consolidating its numerous regulations into one comprehensive law.

The draft PDPD was released for public consultation in February 2021 and was originally scheduled to take effect in December 2021.¹⁹⁶ At the time of writing, the draft PDPD is still pending enactment, although a revised version appears to have been approved with the government’s issuance of Resolution No. 27/NQ-CP in March 2022. That version has yet to be disclosed. It appears that with the Resolution’s authorization of the MPS to further develop the PDPD in consultation with the Standing Committee of the National Assembly (SCNA), other amendments may be possible. As of the time of writing, this process seems likely to cause further delay to the enactment of the PDPD as the MPS is not due to submit the final version of the PDPD to the government for issuance till May 2022.¹⁹⁷

Similarly, the draft cybersecurity decree was released for comments from September to November 2021, with an expected promulgation date soon after. As of the second quarter of 2022, however, its enactment remains forthcoming. Paradoxically, although this document offers clarifying guidelines to several provisions of Viet Nam’s controversial Law on Cybersecurity 2018, the draft cybersecurity decree differs from the Law on Cybersecurity by taking a narrower approach to data localization, perhaps in response to industry’s forceful representations.¹⁹⁸ Given the decree is meant to operationalize the law, it will be interesting to see how this divergence is resolved when the final version of the decree takes effect.

The government’s data localization requirement has been one of the most scrutinized aspects of its data governance framework, seen by business and industry as prohibitive to the development of a robust and secure digital economy, but viewed by the government as fundamental to preserving digital sovereignty and “social order and safety.”¹⁹⁹ For Hanoi, striking a balance between the two is proving an urgent challenge, particularly in light of its commitments under the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) and the country’s newly-issued National Strategy for Development of Digital Economy and Digital Society by 2025, Orientation to 2030.

Prime Minister Phạm Minh Chính’s January 2022 decision (Decision 06/QD-TTg) “to approve the Scheme on developing the application of data on population, identification, electronic authentication data for national digital transformation in the 2022-2025 period, with a vision toward 2030” paves the way for a full-fledged personal data protection law that would be more comprehensive than the PDPD.²⁰⁰ The decision directs the MPS to conduct research and consultation to draft such a law by 2024.

Usage and impact

Consultations with informants revealed that tensions between the utility of data flows to advance the economy, on the one hand, and its implications for national security, on the other, pervade the discourse on data governance in Viet Nam.

Data for the digital economy

Viet Nam’s goal is for the digital economy to account for 20 percent of its gross domestic product (GDP) by 2025. In the first half of 2021, one year into the pandemic, more than half (55 percent) of the country’s eight million new digital consumers logged on from non-metro areas. Its e-commerce sector grew 53 percent year-on-year in 2021 and its overall internet economy is projected to reach USD57 billion in value by 2025.²⁰¹

Yet, despite this bullish commercial outlook, Hanoi remains conscious about the headwinds it faces, especially against the backdrop of recovery from the pandemic, in order to achieve the 20 percent digital economy goal it set out for itself over the next three years. That would require maintaining an average annual growth of the digital economy at about 20 percent, a rate three times higher than the expected annual GDP growth.

Under normal circumstances, the Ministry of Information and Communications estimates that the digital economy will account for only 10.4 percent of GDP by 2025, with the ICT, telecommunications, and internet economy together accounting for about 7.9 percent of GDP. With an emphasis on digital transformation, the digital economy could reach 19.9 percent of GDP. A “breakthrough scenario”, however, could see the digital economy contributing 26.2 percent to GDP, surpassing the 20 percent target rate. This would warrant the concerted development of national strategies and programs; the review and amendment of certain laws, mechanisms, and policies; and an acceleration of the implementation of the National Digital Transformation Program, including skills training.²⁰²

Over the last few years in Viet Nam, there has been growing recognition that domestic reforms will have to be made in order for this digital transformation to keep pace with the government’s agenda.²⁰³ Since data drives digital transformation, Hanoi must achieve a fine balance between enabling data flows for ease of business and regulating it enough to ensure data is protected. In the face of domestic constraints, external pressures sometimes help. In November 2018, Viet Nam ratified the CPTPP. On January 2019, the CPTPP entered into force in the country, starting the five-year clock for Hanoi to realign its data localization requirements with its obligations under the CPTPP’s e-commerce chapter.

Viet Nam’s position on data localization is primarily outlined in three of its legal instruments: the Law on Cybersecurity 2018, the draft cybersecurity decree, and the draft PDPD. Of the three, the Law on Cybersecurity is broadest in scope. Article 26 states that all domestic and foreign enterprises offering services “on telecommunication networks or the internet and value-added services in cyberspace in Viet Nam” must locally store data related to those services for a period specified by the government. Foreign companies must also establish a branch or representative office in Viet Nam. There are no exceptions to this provision.

By contrast, Article 26 of the draft cybersecurity decree narrows the scope of localization to when the foreign provider has full knowledge that their service or platform is being used to commit offences and the provider fails to mitigate or remedy the situation.²⁰⁴ Additionally, the mandate for localization only applies to foreign companies engaged in certain services. These include telecommunications, data storage, domain name service, e-commerce, online payment, social networking and media, and online electronic games. However, this list remains an expansive one and industry players have urged for localization to be restricted to only the most sensitive national security data, if necessary, and for localization to exclude enterprises that do not disseminate information to the public, such as enterprise software and cloud service providers.²⁰⁵

The initial version of the draft PDPD circulated for public comments stipulates four conditions determining the transfer of personal data from Viet Nam abroad. These are consent from the data subjects, storage of the original data in Viet Nam, proof of the recipient country having at least equivalent personal data protection levels (the “adequacy” requirement), and a written approval for transfer from the Personal Data Protection Commission (PDPC). The draft PDPD also requires data controllers or processors that transfer data abroad to store data transfer history for three years.²⁰⁶

An exemption may be applied to all these conditions. However, this exemption is itself conditional on consent from the data subject, PDPC approval, a commitment of data protection from the data processor, and/or a commitment from the data processor to apply data protection measures. It is unclear if the data transferor will need to meet any or all four conditions to be exempt.

Since the approved version of the draft PDPD has not yet been released, the question remains whether these provisions will make the final cut of the decree, given the foreseeable compliance costs and delays businesses will face.²⁰⁷ In its comments on the outline of the draft PDPD in November 2020, the Asia Internet Coalition, comprising technology giants such as Airbnb, Amazon, Expedia Group, Facebook (Meta), Google, and Grab, expressed concern that the restriction of cross-border data flows would not only hinder investment and innovation but could also result in greater cyber insecurity. 

Data for public policy

Viet Nam’s digital transformation plans for improved public services delivery can be traced back to the mid-2000s.²⁰⁸ In 2018, frustrated by the slow implementation of the 2010-2020 Master Program on Public Administration Reform, the then prime minister Nguyễn Xuân Phúc (now Viet Nam’s president) established a high-level national committee for e-government comprising ministers and industry leaders to improve public administration and the business environment, as well as eradicate fraud and corruption. The government even reached out to Japan for support in fast tracking the operationalization of Viet Nam’s e-government policy.²⁰⁹

In June 2021, the prime minister issued the country’s very first e-government strategy (Decision No. 942/QD-TTg), with specific efficiency targets to be achieved by 2025. These include requirements for people to declare their data only once, for at least 80 percent of administrative documents to be wholly processed online, for 100 percent of state agencies to provide online services around-the-clock, for 100 percent of officials to have digital identities, and for each citizen to possess a digital identity and QR code.²¹⁰ Significantly, the strategy calls for an assertive push to develop national databases on Viet Nam’s population, land, and enterprises, with specialized, sectoral data on finance, insurance, agriculture, and health, among others, in order to achieve its goal of being ranked by the United Nations as one of the world’s top 30 countries in e- and digital government by the year 2030. In 2020, Viet Nam ranked 86^th out of 193.²¹¹ This 2021 strategy is simply one component of the government’s larger national digital transformation plan, in addition to its various other resolutions and strategies on the Fourth Industrial Revolution and sustainable development.²¹²

In response to the COVID-19 pandemic, Viet Nam rolled out several digital health applications, most of which were new, although at least one had long been in existence and was adapted to account for the coronavirus. The national electronic Communicable Disease Surveillance system (eCDS) was the first nationwide, computerized collection of case data on hospital admissions. It was developed in 2004, and over the years surveilled outbreaks of dengue; hand, foot, and mouth disease; severe acute respiratory infections; and Zika. However, the limitations of the eCDS in capturing follow-up case information prompted the Ministry of Health to develop a COVID-19-specific online case management software for control measures and risk communication.²¹³

As in neighboring countries in Southeast Asia, Viet Nam also deployed a Bluetooth-based contact tracing app, with theirs called Bluezone. Unsurprisingly, the app raised privacy concerns among some, despite the government’s assurances of confidentiality, anonymity, and transparency. This apprehension was accentuated by larger misgivings about state surveillance under Viet Nam’s model of government. However, a privacy review of contact tracing apps in Southeast Asia by a local team from the International Association of Privacy Professionals found that Bluezone, together with Singapore’s TraceTogether app, actually used the least number of permissions to perform its functions when compared against other apps.²¹⁴ MIT Technology Review’s larger survey of 25 contact tracing apps around the world credited Bluezone for using a voluntary, decentralized, and transparent system, but found that the app nevertheless required access to contacts and other media such as photos on the user’s mobile device.²¹⁵

Although there was a low initial uptake of only about 100,000 downloads of Bluezone when it was launched in April 2020, that number shot up to 20 million in a span of only four months as a government campaign galvanized public support for doing the right thing by protecting the individual, community, and country.²¹⁶ Any unease about the data security and privacy of Bluezone seemed to have been overridden by a stronger sense of community and public confidence in government in the earlier stage of the pandemic.²¹⁷ However, that confidence dipped dramatically among policy elites as Hanoi’s performance rating took a hit in 2022 after the surge of the COVID-19 Delta variant and a slow national vaccination roll-out in 2021.²¹⁸

---

Case Study

Data Sheds Light on Violence against Women 

In 2010, a nationwide survey conducted by the General Statistics Office (GSO) of Viet Nam shed light on the prevalence and severity of the violence experienced by women on a nationwide scale. Fifty-eight percent of women reported experiencing physical, sexual, or emotional abuse by their husbands, and 87 percent had not sought any form of help.

Prior to the survey, little was known about the true extent of the violence women faced in Viet Namese society, as it was traditionally viewed as a private family affair which was not to be discussed in public settings. The Vietnamese authorities had no information to guide policymaking and government strategies and it was difficult to improve the legal framework or challenge the cultural stigma surrounding the issue.

The survey collected both qualitative and quantitative data to capture a comprehensive picture of the situation in Viet Nam. The data marked the start of a new era in promoting gender equality in Viet Nam. It “catalyzed a public conversation about the nature of violence against women, raised awareness around coping strategies and available support services, and informed new government strategies and policy responses addressing violence against women.”

---

Challenges and prospects

Hanoi’s drive to digitally transform Viet Nam’s governance, economy, and society is palpable from the many decisions, resolutions, and strategies that the country’s leaders have issued over the years. Political will, therefore, is not in short supply.

Rather, Viet Nam will have to overcome several other hurdles as it seeks acceleration on the digital superhighway. These include upskilling and building human resource capacity, enhancing cybersecurity, and improving the country’s digital infrastructure ecosystem sustainably, all of which were raised in our expert consultations and have also been discussed extensively elsewhere.²¹⁹

Consolidation of legal instruments

However, as discussed above, the immediate imperative is for Viet Nam to consolidate and reconcile its array of legal regulations, especially those related to localization. An added complication is the disjuncture between the language of some of these regulations, on the one hand, and how they are enforced, on the other.²²⁰ The drafts of the cybersecurity and PDPD decrees are cases in point. Further, as informants noted, valid concerns about managing cybersecurity risks and fraudulent online content can lead to the formulation of overly rigid and prescriptive draft regulations that could, in turn, result in unintended negative consequences. Viet Nam’s amendments to Decree 72 on the Management, Provision, and Use of Internet Services and Online Information was cited as an example of regulatory obligations that were extended to cloud service providers without recognizing the shared responsibility model of cloud computing or its restrictive effects on cross-border data flows.²²¹ Moving forward, Hanoi will have to ensure that legal instruments regulating data capture, storage, or transfers are specific and predictable enough for both large and small businesses to operate, but also sufficiently flexible to anticipate, or respond to, changes in the digital landscape.

The requirement of explicit consent for businesses to collect data, such as through pop-up windows on websites or applications, would strengthen data privacy in the country, a particular concern given that the practice of selling phone lists to spammers or sending bank details via unencrypted chats has run rampant.²²² However, the regulation would also be difficult to implement since 80 percent of Viet Nam’s cloud computing²²³ segment comprises foreign companies that have already urged the country to align “with global approaches” to avoid damaging Viet Nam’s plans for digital transformation.

There is also the risk that once Viet Nam’s five-year grace period under the CPTPP ends, these data localization requirements could put the country in breach of its treaty obligations. The CPTPP obliges parties to allow the cross-border transfer of information by electronic means and does not require the use or location of computing facilities in-territory. While the draft PDPD does not appear to accord with either of these provisions, there is a “legitimate public policy objective” under the CPTPP that Hanoi could take advantage of, provided the related policies do not create “disguised barriers to trade or are applied in a discriminatory or arbitrary fashion.” Currently, CPTPP parties have agreed not to sue Viet Nam if its regulations are deemed inconsistent with the agreement.²²⁴ Groups such as the Global Data Alliance have urged Viet Nam to account for its CPTPP commitments in its PDPD review process.²²⁵

Inclusion and representation

Relatedly, as Viet Nam seeks to draw foreign investment to grow its digital economy, it will have to pay close attention to its smaller, local businesses. Micro, small, and medium enterprises (MSMEs) make up 95 percent of all firms in Viet Nam, 40 percent of GDP, and employ 50 percent of the country’s workforce.²²⁶ Although an overwhelming number of SMEs (96.9 percent) in Viet Nam think that digital transformation plays an important role, up to 70 percent are still operating outside the digital economy and only around 20 percent are “tentatively exploring it.”²²⁷ More than half of them (57.6 percent) have insufficient resources to deploy digitalization tools in their business operations because they are either simply too preoccupied with sustaining their businesses, are unfamiliar with digital platforms, or have inadequate support to migrate their enterprise online.²²⁸ The impact of data regulations should thus not be a barrier to entry to the digital economy for these MSMEs. Instead, given their outsized participation in the economy, MSMEs could not only be supported in this area through business-to-business-type capacity-building initiatives but also actively courted for consultations in the drafting and promulgation of the relevant rules.

There is a compelling need to support women-owned MSMEs, in particular, and to ensure that data collected on them is accurate in order for them to be adequately represented in Viet Nam’s digital economy. With women constituting half of Viet Nam’s population, any successful effort at digitalizing both the country’s economy and society should include a considered gender dimension. After all, women-owned SMEs account for 98.8 percent of MSMEs and 25 percent of SMEs in the country. Compared to men-owned SMEs, they employ a higher percentage of female workers (43.3 percent versus 36 percent), contribute marginally more to the national budget in taxes per worker per year (VND24.9 million versus VND24.2 million), and contribute slightly more in social insurance payments (36 percent versus 35 percent).²²⁹

In general, Viet Nam’s extension of a supportive ecosystem for women in business is boosted by, for example, preferential measures and training incentives for women-owned SMEs.²³⁰ The government has also long had a National Gender Equality Strategy which mentions support for women-owned SMEs, although it lacks a precise definition of the category. In 2021, the government extended this strategy for another 10 years to 2030, in furtherance of its commitment to SDG5 on gender equality and women’s empowerment. Among other updates, the strategy outlines the development of a national gender statistical database. It also affords flexible online training programs on digital technology for women-owned SMEs. This flexibility will be especially helpful given the harder impact of COVID-19 on women-led MSME revenues, perhaps a result of differentiated expectations related to home-care responsibilities.²³¹

Inclusion through data is also reflected in the question of where Viet Nam’s ethnic minorities place in the country’s digital development agenda: a point that is not lost on the government itself. Hanoi has acknowledged the high poverty rate, difficulty of access to quality and inclusive education, and significant gender gap among the country’s ethnic minorities. In 2019, the government passed a resolution approving the Master Plan on Socio-economic Development of Ethnic Minorities and Mountainous Areas, which includes promoting science and technology transfer and developing a comprehensive database on ethnic minority groups for policy planning and implementation. Partnering with industry and international financial institutions, the government has also sought to advance digital inclusion for ethnic minorities and rural students.²³² A pilot project financed by the World Bank, for example, has enabled the Viet Namese government to pay out social assistance to ethnic minorities in Cao Bang province by way of mobile money instead of requiring them to collect cash in person on one or two fixed days a month.²³³

As nations seek digitalization, representation through data is important even if, but perhaps especially when, digital and traditional ways of life do not neatly intersect. In the past, land development contrary to indigenous practices created frictions between the state and these communities. In response, the Culture Identity and Resources Use Management (CIRUM) non-governmental organization has worked with 19 different ethnic minority groups in upland forested provinces in northern Viet Nam, and even neighboring countries, to collect data on the health and well-being of native communities impacted by these development activities. This data-based advocacy approach resulted in the passing of Viet Nam’s Law on Forestry in 2017, and ethnic minority groups reclaiming their customary rights to the land and its natural resources. 

The idea of data collection by, on behalf of, or for, ethnic minority groups restores their agency, authority, and dignity within the context of the state. It also responds in part to criticisms that government policies inadequately meet the specific needs of different ethnic minority groups and take a top-down, rather than an organic, bottom-up approach. Multi-stakeholder consultations involving policy-makers can also facilitate more effective conflict management or resolution in these areas. CIRUM’s use of Google Maps to plot land use rights is a simple yet effective way to mitigate conflict between customary and state laws on land use, and promote transparency on the issue.

Representation through data is but a first step to being “seen” and included in the digital world. That representation must also be protected accordingly, especially among underserved and vulnerable segments of society such as ethnic minority groups, the poor, differently-abled, and children. This is particularly necessary since it may be a while before all minority and marginalized groups are adequately taken into account in the deployment, let alone in the design and development, of digital tools. It explains why, in the meantime, there is a growing body of work calling for privacy rights for vulnerable sections of the population to be reinforced rather than relaxed for the convenience of access to state benefits.²³⁴ In Viet Nam, the right to privacy is constitutionally guaranteed and likely to be preserved in an eventual comprehensive data protection law. The country is therefore already well-placed to expand on protecting the data of its most vulnerable populace—and by extension those communities themselves—should it choose to.

Standards and norms

As Viet Nam navigates its nationwide digitalization efforts, the government’s key challenge will be to liberalize its data governance regime, in order to compete more effectively at the international level, without compromising its domestic authority over social and security matters in the digital space. According to one informant, greater awareness of related issues will need to be raised domestically to facilitate wider public deliberation, especially as Viet Nam contemplates adapting different international approaches to data governance to meet its needs. Reflecting on large, external players setting the rules, the informant raised the possibility of Viet Nam working together with other ASEAN nations to craft a middle approach at the regional level that could accommodate the pressures of digital trade liberalization—and correspondingly appropriate data governance frameworks—while preserving state autonomy.²³⁵

The notion of participating more actively in standards setting is key to ensuring agency and, as one informant reminded us, is even more so in the current climate in which great power competition is spilling over into the technology arena. Viet Nam’s Directorate for Standards, Metrology and Quality (STAMEQ) under the Ministry of Science and Technology already represents the country in 14 international and regional organizations.²³⁶ Viet Nam is also a member of the International Telecommunication Union, although not of the 3GPP initiative, despite its local development of 5G technology.

Conclusion

Viet Nam’s adaptation of different legal regimes, including the EU’s GDPR and China’s cybersecurity law, into its domestic framework reflects the country’s characteristic resolve to continue preserving its policy space and independence in the digital data domain. The government is keenly aware of what needs to be done in all the different areas outlined above in order to drive its vision of national digital transformation. Hanoi’s ratification of the CPTPP, domestic challenges notwithstanding, is illustrative of that cognition as are the ambitious reform targets over the next decade it has set out for itself. 

As Viet Nam streamlines these internal initiatives, the logical extension to its digital strategic autonomy in the near future would be for the country to increasingly contribute to international rule-making in various forums related to data governance. Hanoi’s endorsement and observance of non-binding regional tools such as the ASEAN Data Management Framework would affirm budding collective coherence. More significantly, similar coordination efforts by Viet Nam together with other ASEAN member-states at the regional level could set the stage for greater norms alignment at the international level.

---

Selected Legal Instruments Related to Data Protection in Viet Nam

1. Cybersecurity
   Law No. 24/2018/QH14 Cybersecurity Law
2. Cybersecurity
   Law No. 35/2018/QH14 Network Information Security Law
3. Cybersecurity
   Decree No. 85/2016/ND-CP Security of Information
4. Cybersecurity
   Decree No. 72/2013/ND-CP on Management, Provision and Use of Internet Services
5. Cybersecurity
   Law No. 86/2015/QH13 Law on Network Information Security
6. Data Protection
   Draft Decree on Personal Data Protection
7. Data Protection
   2013 Constitution of the Socialist Republic of Viet Nam
8. E-Commerce/Transactions
   Law No. 51/2005/QHII on E-transactions
9. E-Commerce/Transactions
   Law No. 36/2005/QH11 on Commerce
10. E-Commerce/Transactions
    Law No. 61/2020/QH14 on Investment
11. E-Commerce/Transactions
    Decree 52/2013/ND-CP on E-commerce
12. E-CommerceDecree 09/2018/ND-CP guiding the Law on Commerce and the law on Foreign Trade Management/Transactions
13. Information Technology
    Law No. 67/2006/QH11 Law on Information Technology
14. Information Technology
    Law No. 21/2017/QH14 IT Law

---

Endnotes

¹⁹⁶ “Draft Decree: Provisions on Protection of Personal Data [Dự thảo Nghị định quy định về bảo vệ dữ liệu cá nhân],” Vietnam Ministry of Public Security, February 9, 2021.

¹⁹⁷ Manh-Hung Tran, “Vietnam: Data Privacy Rules - from a Draft Decree to a full Data Privacy Law,” Baker Mckenzie, February 28, 2022.

¹⁹⁸ “Joint Industry Comments on May 24 Revised Draft Law on Cybersecurity,” US-ASEAN Business Council, Asia Internet Coalition, BSA | The Software Alliance, Japan Electronics and Information Technology Industries Association and Information Technology Industry Council, May 28, 2018.

¹⁹⁹ “Law on Cybersecurity,” National Assembly, June 12, 2018.

²⁰⁰ “Decision No. 06/QD-TTg 2022 the application of data on population for national digital transformation 2022-2025,” Ministry of Public Security, January 6, 2022; Manh-Hung Tran, “Vietnam: Data Privacy Rules - from a Draft Decree to a full Data Privacy Law,” Baker McKenzie, February 28, 2022.

²⁰¹ Aadarsh Baijal et al., “e-Conomy SEA 2021: Vietnam,” Bain & Company, Google and Temasek, November 10, 2021.

²⁰² “Three scenarios to help digital economy breakthrough by 2025,” VietnamPlus, January 19, 2022.

²⁰³ See, e.g., Alicia Cameron et al., “Vietnam’s future digital economy – Towards 2030 and 2045,” Commonwealth Scientific and Industrial Research Organisation, 2019, 37.

²⁰⁴ See, e.g., Manh-Hung Tran, “Vietnam: Update on Data Localization Requirement & Cross-border Data Flow,” Baker McKenzie, March 15, 2022.

²⁰⁵ “BSA Comments on Draft Decree on Sanctions against Violations in the Field of Cybersecurity,” BSA | The Software Alliance, November 18, 2021.

²⁰⁶ See, e.g., Manh-Hung Tran, “Data localization requirements in Vietnam,” Baker McKenzie, July 26, 2021; Manh-Hung Tran, “Vietnam: Update on Data Localization Requirement & Cross-border Data Flow,” Baker McKenzie, March 15, 2022; “Data Protection Laws of the World: Vietnam,” DLA Piper, January 10, 2022.

²⁰⁷ “Vietnam Issues New Draft Decree on Personal Data Protection,” Tilleke & Gibbins, February 25, 2021.

²⁰⁸ Do Lap Hien, “E-Government Policy of Vietnam” (paper presented at the 3rd Asia-Pacific Regional Forums on Smart Cities and e-Government 2017, Bangkok, Thailand, September 2017).

²⁰⁹ “Data Collection Survey On E-Government In Vietnam,” Japan International Cooperation Agency (JICA) Fujitsu Research Institute, June 2019.

²¹⁰ “Decision No. 942/QD-TTg 2021 the e-Government development strategy in 2021 - 2025,” Ministry of Information and Communications, June 15, 2021.

²¹¹ “UN E-Government Knowledgebase: Viet Nam,” United Nations Department of Economic and Social Affairs, accessed May 23, 2022.

²¹² Resolution No. 52-NQ/TW of the Central Committee on a number of guidelines and policies to actively participate in the Fourth Industrial Revolution, September 27, 2019; Resolution No. 50/NQ-CP promulgating Resolution No. 52-NQ/TW, April 17, 2020; Decision No. 749/QD-TTg approving the national digital transformation program through 2025, with orientations toward 2030, June 3, 2020; in Decision No. 2289/QD-TTg issuing the National Strategy on the Fourth Industrial Revolution to 2030, December 31, 2020; Resolution No. 136/NQ-CP on sustainable development, September 25, 2020. See also, “Viet Nam issued its first e-government strategy towards digital government,” Ministry of Information and Communications, June 15, 2022.

²¹³ Long V. Bui, “The Contribution of Digital Health in the Response to Covid-19 in Vietnam,” Front. Public Health 9:672732 (2021), doi: 10.3389/fpubh.2021.672732.

²¹⁴ Kevin Shepherdson, “How intrusive are contact-tracing apps in ASEAN?” Tech in Asia, June 23, 2020.

²¹⁵ Patrick H. O'Neill, Tate Ryan-Mosley, and Bobbie Johnson, “A flood of coronavirus apps are tracking us. Now it’s time to keep track of them,” MIT Technology Review, May 7, 2020.

²¹⁶ “Bluezone electronic mask application surpasses 100,000 users [Ứng dụng khẩu trang điện tử Bluezone vượt mốc 100.000 người dùng],” ICTNews, April 28, 2020; “Bluezone COVID-19 tracing app records 20 million downloads,” VOVWORLD, August 21, 2020.

²¹⁷ Dien Nguyen An Luong and Benjamin Hu, “Fighting Covid-19 in Vietnam: Striking a Delicate Balance Between Public Safety and Privacy,” ISEAS-Yusof Ishak Institute, August 21, 2020.

²¹⁸ Sharon Seah et al., “The State of Southeast Asia 2022 Survey Report,” ISEAS-Yusof Ishak Institute, February 16, 2022.

²¹⁹ See, e.g., Alicia Cameron et al., “Vietnam’s future digital economy – Towards 2030 and 2045,” Commonwealth Scientific and Industrial Research Organisation, 2019.

²²⁰ Alicia Cameron et al., “Vietnam’s future digital economy – Towards 2030 and 2045,” Commonwealth Scientific and Industrial Research Organisation, 2019, 37.

²²¹ Stakeholder consultation.

²²² Lien Hoang, “Big Tech warns Vietnam data rules risk 'damage' to digital economy,” Nikkei Asia, November 17, 2021.

²²³ “Vietnam’s cloud computing market worth $133 million,” Ministry of Information and Communications, November 25, 2020.

²²⁴ “CPTPP: Viet Nam’s commitments in some key areas,” Ministry of Industry and Trade, accessed May 23, 2022.

²²⁵ Eunice Lim, “Comments on Proposed Amendments to Draft Decree 72,” Global Data Alliance, December 30, 2021.

²²⁶ “Enterprises,” General Statistics Office of Vietnam, accessed May 23, 2022. 

²²⁷ “Why digital transformation holds huge potential to grow Vietnam’s economy,” Vietnam Insider, January 25, 2022. 

²²⁸ “Over 57.5 per cent of Vietnamese SMEs struggle with digital transformation: How can they cope with the challenge?,” Vietnam Investment Review, April 19, 2021. 

²²⁹ Le Quang Canh and Nguyen Vu Hung, “Women-Owned Small And Medium-sized Enterprises In Viet Nam: Situation Analysis And Policy Recommendations,” Mekong Business Initiative of the Asian Development Bank and the Hanoi Women’s Association of Small and Medium Enterprises, September 2020. 

²³⁰ Cece Nguyen, “Vietnam Implements Gender Equality Strategy but Challenges Remain,” Vietnam Briefing, December 6, 2021. 

²³¹ “Assessment of the Impact of COVID-19 on MSMEs, and especially women-led MSMEs, in Viet Nam,” United Nations Economic and Social Commission for Asia and the Pacific, 2020. 

²³² Alicia Cameron et al., “Vietnam’s future digital economy – Towards 2030 and 2045,” Commonwealth Scientific and Industrial Research Organisation, 2019. 

²³³ “Vietnam: Mobile Technology Enables Faster and Safer Social Allowance Transfers for Ethnic Minorities,” March 27, 2020, World Bank, video.

²³⁴ See, e.g., Michael Pisa et al., “Governing data for development: Trends, challenges, and opportunities”, Center for Global Development, Policy Paper No. 190, November 12, 2020; David Medine and Gayatri Murthy, “Making Data Work for the Poor: New Approaches to Data Protection and Privacy,” Consultative Group to Assist the Poor, January 2020; Robert Gellman, “Privacy and Biometric ID Systems: An Approach Using Fair Information Practices for Developing Countries,” Center for Global Development, Policy Paper No. 190, August 01, 2013.

²³⁵ Stakeholder consultation.

²³⁶ “STAMEQ Members: Viet Nam,” International Organization for Standardization, accessed May 23, 2022.