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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · DATA-CLASSIFICATION

Filed under data-classification

Every brief tagged "data-classification".

  • § 01 · IMPORTANT-DATA

    'Important Data' Is a Category, Not a Tier

    Hong Yanqing argues the mainstream reading of Article 21 of the Data Security Law confuses enterprise asset-inventory language with state-level legal-interest protection — with real consequences for cross-border transfers, enforcement, and how PIPL and DSL stack.

    important-data · dsl · commentary
  • § 02 · IMPORTANT-DATA

    How to Identify 'Important Data' — A Plain-Language Method from Wang Qinglan

    Wang Qinglan, head of compliance at a Chinese data exchange, walks through China's unique 'important data' concept in plain language: where it came from, why no other major jurisdiction has anything quite like it, how the U.S., EU, Japan and Korea solve the same problem differently, and — most useful for compliance teams — three methods to identify whether a dataset is 'important' in practice. Her own 'unorthodox' shortcut: ask whether a hostile foreign actor could use this data to cause trouble. If yes, treat it as important data.

    important-data · data-classification · cross-border
  • § 03 · 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
  • § 04 · 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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