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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ BRIEFINGS · PAGE 18

Every brief.

The full run, most recent first.

  • § 103 · 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
  • § 104 · 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
  • § 105 · PUBLIC-DATA

    Case Study — A Public-Data Operator Hands Personal Data to a Bank. Two Compliance Failures.

    A real-case analysis from Wang Qinglan. A state-affiliated auction company holds the public-data operating right for vehicle license-plate auction data. A bank persuades it to hand over the personal data of winning bidders. The bank builds a targeted credit product and pays the auction company RMB 12 million a year in revenue share. Two compliance failures: (1) no individual consent under PIPL; (2) no credit reference business license under the Credit Reference Industry Regulation and Credit Reference Business Measures. Public-data authorized operation does not displace the credit reference licensing regime.

    public-data · credit-reference · authorized-operation
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