Filed under structural-separation
Every brief tagged "structural-separation".
- § 01 · DATA-PROPERTY-RIGHTS
NDA Explains the Three-Rights Framework — A Plain-Language Walk-Through from the Regulator Itself
The National Data Administration's official 政策解读 (policy interpretation) on the three-rights framework — the right to hold, the right to use, and the right to operate data — established by the Data 20 Articles. NDA walks through what each right means, illustrative scenarios (group-company data subsidiaries; hospital-pharma research pools; data-broker commission arrangements), how the rights relate to each other (independently severable; non-exclusive across parties for the same data), and why the structural-separation design was chosen over a unitary-ownership model. The clearest available statement of the regulator's own intent on the framework that anchors every downstream rule — data-resource registration, data-property-rights registration, FTZ data-circulation negative lists, on-floor / over-the-counter trading rules.