China: Consultation closed on Shanghai Data Regulations Draft including data governance liability

On 20 October 2021, the Shanghai Municipal Government closed the consultation on the draft Shanghai Data Regulations. The draft Regulations stipulate fines for private entities unlawfully creating unfair trading conditions through the use of data or unlawfully trading in data. Violations can also lead to credit penalties, and, in serious cases where the rights of a large number of individuals are infringed, a lawsuit may be filed by the relevant public authorities.