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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ BRIEFINGS · PAGE 13

Every brief.

The full run, most recent first.

  • § 73 · DATA-FUNDAMENTALS

    What Is Data, Really? — A Plain-Language Primer on Rules and Compliance

    What does it actually mean to call something 'data,' and what turns raw recordings into a data asset? Wang Qinglan uses a toy storage room metaphor to walk through the foundational concept overseas readers often skip: data is not just 'records' — it's records made under rules. Master data, metadata, ontology, the three-tier compliance taxonomy (legal / ethical / promised), and the three-step compliance workflow (select / allocate / execute) — all anchored in a concrete example a non-specialist can follow.

    data-fundamentals · data-governance · compliance-architecture
  • § 74 · DATA-GOVERNANCE

    Data Governance vs. Data Management vs. Data Compliance — A Plain-Language Disambiguation

    Wang Qinglan disambiguates three terms that compliance and data teams habitually conflate: data governance, data management, and data compliance. Using a 'data manor' metaphor (the family council vs. the steward team vs. the community monitor), she maps each function to its job — setting direction, executing efficiently, and operating sustainably within external rules and self-imposed commitments. The piece is useful precisely where bilingual confusion is highest: 'data governance' in English carries different connotations than 数据治理 in Chinese practice.

    data-governance · terminology · dama
  • § 75 · CROSS-BORDER

    FTZ Data Export Negative Lists — How 17 Sectors Across Seven Provinces Now Identify Important Data

    Article 6 of the 2024 CBDF Provisions authorized Free Trade Zones to publish data-export negative lists. Since then, Tianjin, Beijing, Hainan, Shanghai, Zhejiang and others have published negative lists covering 17 sectors — automotive, pharmaceuticals, retail, civil aviation, reinsurance, deep-sea industry, seed industry, and more. Compliance Talker's analysis walks through the structural convergence of the negative lists, the important-data identification refinements each FTZ has produced, and the operational impact on enterprises both inside and outside the FTZs.

    cross-border · important-data · ftz-negative-list
  • § 76 · DATA-PROPERTY-RIGHTS

    What Does Data Registration Actually Confirm? — A Doctrinal Reading

    Long before the SPC's January 2026 'data disputes' case category started squeezing data registration certificates against judicial review, Wang Qinglan had already written the foundational critique: data registration does not 'confirm rights' because there are no legal data rights to confirm. The Data 20 Articles created data property rights, not data legal rights, and Chinese property rights are not Article-conferred civil rights. Registration certificates are 'trust credentials,' not 'rights certificates.' This is the doctrinal essay overseas counsel should read before the SPC sequel.

    data-property-rights · data-registration · civil-law-doctrine
  • § 77 · DATA-EXCHANGES

    On-Exchange vs. Off-Exchange Data Trading — A Uniquely Chinese Market Structure

    Why does China have data exchanges? Wang Qinglan's piece opens with an observation overseas readers will recognize: 'When you tell foreigners about China's on-exchange data trading market, you get blank stares — because exchange-organized data trading is uniquely Chinese.' The analogy she offers — Shenzhen Data Exchange is to data what the Shenzhen Stock Exchange is to securities — unlocks the architecture. Five tiers of trading venues by public-risk level. Three waves of Chinese data-exchange evolution. And the operational meaning of why on-exchange and off-exchange trading coexist.

    data-exchanges · data-economy · szdex
  • § 78 · DATA-ECONOMY

    What Is Actually Traded on China's Data Exchanges — A Bakery Metaphor

    Per the Shenzhen Provisional Measures for Data Trading Administration, four categories of object can be traded on a Chinese data exchange: data products, data services, data tools, and other regulator-approved objects. Wang Qinglan walks through what each means in plain language with a bakery metaphor — wheat (raw data) becomes flour (data resources) becomes cakes (data products); a baker is a data service; the oven is a data tool. The piece is useful precisely because it answers a question overseas teams rarely think to ask: what are the data exchanges actually selling?

    data-economy · data-trading · data-products
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