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GB/T 37932-2025Data security technology - Security requirements for data transaction services (English PDF)

数据安全技术 数据交易服务安全要求

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Issued by

SAMR; SAC

Level / Type

National · Recommended

Issue date

December 2, 2025

Implementation date

July 1, 2026

Scope

GB/T 37932-2025 is the English-translated version of 数据安全技术 数据交易服务安全要求.

GB/T 37932-2025 is the Chinese national standard on the security of data transaction services. It sets security requirements for the participants in a data transaction, for the transaction platform, for the object traded and for the transaction process.

It describes the reference model for in-site and off-site transactions, the end-to-end process from entity onboarding through negotiation, order execution, delivery and settlement to conclusion and supervision, and the kinds of object traded, from datasets and interfaces to reports, tools and services.

It states the security principles that govern them, and an informative annex gives examples of data that may not be traded. It applies to data suppliers, demanders, transaction agencies, providers and third-party professional service agencies, and to regulators and assessment bodies.

It replaces GB/T 37932-2019, was issued on 2 December 2025 and has applied since 1 July 2026.

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Document preview — GB/T 37932-2025

National Standard of the People's Republic of China

ICS
35.030
Classification
L 80
Replacing
GB/T 37932-2019

Issued by: State Administration for Market Regulation; Standardization Administration of the PRC

Contents

  • Foreword3
  • 1 Scope6
  • 2 Normative references6
  • 3 Terms and definitions6
  • 4 General rules9
  • 4.1 Reference model for data transaction services9
  • 4.2 Data transaction process9
  • 4.3 Data transaction object11
  • 5 Security principles for data transactions11
  • 6 Security requirements for data transaction service participants13
  • 6.1 Basic requirements13
  • 6.2 Data supplier14
  • 6.3 Data demander15
  • 6.4 Data provider and data third-party professional service agency15
  • 6.5 Data transaction agency17
  • 7 Security requirements for data transaction platforms19
  • 7.1 Basic requirements19
  • 7.2 Protection of transaction data security20
  • 7.3 Security controls for the transaction process21
  • 7.4 Transaction security audit22
  • 8 Security requirements for data transaction objects22
  • 8.1 Prohibited transaction data22
  • 8.2 Data quality compliance23
  • 8.3 Classification and grading protection of transaction data24
  • 9 Security requirements for data transaction process25
  • 9.1 Entity onboarding, registration and listing25
  • 9.2 Transaction negotiation, order execution26
  • 9.3 Product delivery, transaction settlement27
  • 9.4 Transaction conclusion, supervision and maintenance28
  • Annex A (informative) Examples for prohibited transaction data30
  • A.1 Data that endangers national security and social stability30
  • A.2 Data concerning personal rights and interests30
  • A.3 Data concerning corporate rights and interests31
  • Bibliography32

1 Scope

This document specifies security requirements for data transaction services, including security requirements for data transaction participants, transaction platforms, transaction objects, and the transaction process.

This document applies to data suppliers, data demanders, data transaction agencies, data providers, and data third-party professional service agencies for the purpose of standardizing their data transaction activities. It also applies to regulatory authorities and assessment bodies for the supervision, management, and assessment of data transaction service security.

2 Normative references

The following referenced documents are indispensable for the application of this document. For dated references, only the edition cited applies. For undated references, the latest edition of the referenced document (including any amendments) applies.

GB/T 22239-2019, Information security technology -- Baseline for classified protection of cybersecurity

GB/T 25069, Information security techniques -- Terminology

GB/T 36343, Information technology -- Data transaction service platform -- Transaction data description

GB/T 37988, Information security technology -- Data security capability maturity model

GB/T 43697, Data security technology -- Rules for data classification and grading

3 Terms and definitions

For the purposes of this document, the terms and definitions defined in GB/T 25069 as well as the followings apply.

4 General rules

4.1 Reference model for data transaction services

Data transaction services are categorized into two models. data in-site transaction and data off-site transaction. Data in-site transaction involves suppliers and demanders transacting through a data transaction agency, whereas data off-site transaction takes place outside of such agencies. In actual practice, transactions may take place directly between data suppliers and demanders or through data transaction institutions. Data providers may also participate in the process, providing services such as the development, release, and underwriting of data products and services. Additionally, specialized data third-party professional service agencies may offer legal support, data assetization, security and quality assessments, and training and consulting to facilitate the orderly conduct of data transaction activities. A reference model for data transaction services is shown in Figure 1.

4.2 Data transaction process

The end-to-end process of data in-site transaction typically encompasses stages such as entity onboarding, registration and listing, transaction negotiation, order execution, product delivery, settlement, transaction conclusion, and supervision and maintenance.

Among these, entity onboarding and registration/listing constitute the pre-transaction preparation phase; transaction negotiation, order execution, product delivery, and settlement constitute the execution phase; and transaction conclusion and supervision/maintenance constitute the post-transaction phase. The process of data off-site transaction typically includes stages such as transaction negotiation, order execution, product delivery, settlement, and transaction conclusion. Apart from data transaction agencies, other participants in data transaction must comply with the relevant security requirements set forth in Chapter 9. The data transaction process comprises the following aspects.

a) Entity onboarding. data suppliers, data demanders, providers, and data third-party professional service agencies register with the data transaction institution, completing steps such as user registration, real-name authentication, qualification review, and profile completion.

b) Registration and listing. information regarding the data transaction object is registered, and assessments and reviews are conducted concerning the compliance and quality of data products and services. Data products and services that pass this review are then listed on the data transaction agency.

NOTE 1: The assessment and review are conducted by data transaction agencies or professional data third-party professional service agencies.

c) Transaction negotiation. once the parties to the transaction have connected, they negotiate terms such as the intended use of the subject matter, transaction amount, delivery method, and security responsibilities. The demander may also request data products and services or sample data for testing. Shall further processing of the data products and services be required, the demander may issue a request for such processing to be performed by the data supplier or data provider.

d) Order execution. the data demander selects data products and services and places an order. After the supplier confirms the order details, both parties sign a data transaction contract, and the data transaction agency reviews and files the contract.

e) Product delivery. data products and services are delivered in accordance with the terms of the data transaction contract - whether via a data transaction platform, through a data provider, or through direct delivery between the parties - and the data demander conducts an acceptance review of the delivered products and services.

f) Settlement. settle fees for transaction participants based on the terms of data transaction contracts and payment bills, and support refunds for fees associated with excess purchases.

g) Transaction conclusion. conclude the data transaction, record and archive transaction-related information, conduct audits, and provide after-sales service for the data transaction.

h) Supervision and maintenance. establish mechanisms for handling complaints, reports, and dispute resolution regarding data transactions. Address issues arising from such transactions. Support the review and traceability of illegal or non-compliant data transaction activities, and safeguard the rights and interests of transaction participants.

NOTE 2: Transaction disputes shall primarily be handled by the data transaction agency. If a resolution cannot be reached through coordination, the matter may be referred to expert arbitration or external arbitration bodies.

4.3 Data transaction object

The data transaction object typically involves data products and services such as datasets, data interfaces, data reports, data applications, data tools, data services, and other data-related items.

a) Datasets. a collection of data or a data file that centers on a specific theme and meets user needs.

b) Data interfaces. data accessed via Application Programming Interfaces (APIs) or Software Development Kits (SDKs), such as data verification interfaces and data query interfaces.

c) Data reports. a report presenting the results of data processing - such as statistical analysis and modeling - through visualizations like text and charts.

d) Data applications. data application services or customized solutions provided after data resources have been processed;

e) Data tools. tools providing data processing capabilities such as data acquisition, storage, transmission, preprocessing, processing, visualization, and deletion;

f) Data services. in the process of data transaction, data services - such as data collection, data processing, and security assessment services - are provided by data providers and specialized data third-party professional service agencies.

g) Other data-related items. other data products and services tradable in accordance with the law, such as application accounts, algorithm models, data indices, and encrypted data.

5 Security principles for data transactions

Data transactions adhere to the following security principles.

a) Principle of legality and compliance. the data transaction service participants shall comply with applicable laws and regulations, respect social morals and ethics, adhere to business and professional ethics, and act with honesty and integrity; they shall not endanger national security or the public interest, nor infringe upon the legitimate rights and interests of individuals or organizations.

b) Principle of controllable processes. the data transaction process ensures that data sources are legitimate and verifiable, the scope of use is clearly defined, the transaction process is traceable, and security risks can be prevented.

c) Principles of data classification and grading. the data transaction object must comply with national and industry requirements for classification, grading, and protection. Mechanisms for authorized use and protection - differentiated by data category and grade (such as public data, enterprise data, and personal information) - shall be established, taking into account the scope of data circulation, the extent of potential impact, and associated risks.

d) Principle of ensuring security. the data transaction service participants shall adopt necessary administrative measures and technical means to prevent risks - such as the tampering, destruction, or leakage of transaction subjects, or their unauthorized acquisition, use, or transaction - and to safeguard the rights and interests of personal information subjects.

e) Principle of alignment between rights and responsibilities. participants in data transactions bear security responsibilities for their respective data transaction activities while enjoying the benefits derived from the circulation of data elements.

1) The data supplier is responsible for the quality, security, and compliance of the data transaction object;

2) The data demander is responsible for the security and compliance of the use of the data transaction object;

3) The data transaction agency is responsible for the security of data transaction platforms and the supervision of compliance in the transaction process;

4) The data provider and data third-party professional service agency are responsible for the security, compliance, and professionalism of the data development and utilization process and the products and services provided.

f) Principle of consistency between data in-site transaction and data off-site transaction. with the exception of data transaction platforms and data transaction agencies, other participants in data transaction services must apply the same security management measures and technical means to safeguard data transaction security across both in-site and off-site transaction environments. […]

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This preview omits tables, figures, formulas and parts of the technical clauses. The complete document — 32 pages — is available in the English PDF.

Referenced standards

Editions of GB/T 37932

EditionTitleRevisionStatus
GB/T 37932-2025Data security technology - Security requirements for data transaction servicescurrent editionCurrent
GB/T 37932-2019Data security technology - Security requirements for data transaction servicesprevious editionSuperseded

This page sells the current edition, GB/T 37932-2025. Earlier editions are listed for reference only.

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