With the international development of digital technologies such as cloud computing and big data, the volume of cross-border personal data transmission in scenarios like cross-border e-commerce and social media has grown rapidly. However, at the same time, issues of infringement such as cross-border illegal collection, storage and abuse of personal data have become increasingly prominent, and cross-border relief of personal data rights has become an urgent matter. Against the backdrop of the rapid development of digital technology and trade, cross-border relief for users whose data rights have been infringed upon is an important approach and fundamental guarantee for safeguarding national data sovereignty, maintaining national data security order, and safeguarding the legitimate rights and interests of citizens. It holds significant strategic importance. From an international comparative perspective, the European Union has established a three-in-one governance model of complaint and rights protection-judicial relief - administrative punishment, forming a standardized and strict cross-border protection and governance system for personal data. The institutional innovation of the European Union lies in transforming the high-standard data rights established by the General Data Protection Regulation into operational relief procedures. By setting up an independent data protection bureau and cross-border dispute resolution mechanisms, it ensures that the relief of data rights for EU users is not hindered by jurisdictional boundaries. The United States has improved its cross-border management system for personal data rights through various means such as appointing data protection officers, special defenders, and establishing data review courts. It has also provided efficient relief and legal protection for citizens’ personal data rights by building a cross-border judicial collaboration relief mechanism. In contrast, there is still room for improvement and perfection in China’s awareness of cross-border rights protection among internet users, the construction of relief systems and cross-border collaborative management, as well as the development of relevant institutional platforms. For China, the full-process protection of cross-border personal data transmission and the governance of infringement issues need to be combined with the current implementation status of data entry and exit management regulations and the characteristics of the cross-border personal data transmission environment to promote the construction of a cross-border relief system for personal data rights with Chinese characteristics. At the level of awareness enhancement, it is necessary to strengthen the cross-border protection awareness of personal data rights of internet users through the digital literacy improvement project and improve their own data transmission security protection capabilities. At the level of institutional improvement, it is necessary to accelerate the alignment with international data transmission agreements and establish a three-dimensional cross-border data collaborative management framework that includes judicial mutual assistance, joint law enforcement, and technical certification. At the institutional setup level, the experience of the EU Data Protection Commission can be drawn upon to establish a dedicated cross-border data protection agency, integrate existing regulatory resources, and set up a professional institution for handling cross-border data rights disputes. By establishing a full-cycle management system covering pre-event prevention, in-event response and post-event relief, efforts will be made to enhance China’s rule-making capacity and the level of personal data rights protection in the global data governance system.