The Asia Internet Coalition (AIC) is an industry association formed by eBay, Facebook, Google, and Yahoo! Incorporated. We seek to promote the understanding and resolution of Internet policy issues in the Asia Pacific region.
We appreciate the opportunity to provide comments on Vietnam’s Draft Law on Information Security. Security is fundamental to ensuring that Internet users have a good experience online and that their personal information is protected.
Since technology evolves very rapidly, we suggest that the law avoids being overly prescriptive in order to allow flexibility by companies and by the Government. We suggest, where possible, to limit prescriptive measures to Government systems and critical infrastructure so that private companies are able to continue innovating.
For the law to be enforceable and for companies to have certainty in complying with the law, it is important to be explicit about what is allowed and what is prohibited. Articles that are overly broad should either be clarified or removed.
While AIC companies are happy to work with the Government of Vietnam to address issues like spam and malware, we are concerned that the law may attempt to apply extraterritorially. Foreign companies will be reluctant to cooperate on security matters with the Government of Vietnam if the Law applies extraterritorially. We suggest the Government limit the scope of the law to domestic companies.
Read the comments here: