China: National Data Administration opened consultation on draft model contract for commissioned data processing

On 18 April 2025, the National Data Administration of China opened a consultation, set to close on 18 May 2025, on a draft Model Contract for Commissioned Data Processing for processing data on behalf of another party. This contract outlines obligations for data processors, including data security requirements, confidentiality obligations, restrictions on further delegation, procedures for data delivery and return, and compliance with applicable data protection requirements when handling data under instruction from a data controller.