Subnational variation among provincial data bureaus in China

Abstract

Based on an original overview of the evolution of provincial data bureaus in China between 2014 and 2023, this paper argues that provincial data bureaus between 2014 and 2023 have been an important source of bottom-up data governance practices in China, which are worth studying as part of the broader Chinese data governance regime. To support this argument, the paper provides a descriptive analysis of province-level data bureaus in China up until the establishment of the National Data Administration (NDA) in 2023, with a particular focus on their relationship to the evolving legal concept of ‘public data' in China. The analysis shows that there is substantial subnational variation, exploring the evolution of data bureaus from three different perspectives as examples of data localism: One, considering provincial data bureaus over time, there are significant divergences in when different provinces established theirs, and whether they did so as institutional entrepreneurs or in response to national policy developments. Two, in terms of policy focus, most provincial data bureaus focus on digital public service provision or data-related economic questions, or, increasingly, both. Several data bureaus issued the first set of public data regulations as part of this work, and most were officially responsible for public or closely related concepts. Three, provincial data bureaus have generally been established directly under the provincial government, supervised by a province-level department, or as ‘nameplate’ institutions. This institutional choice matters for the amount of power a data bureau is able to wield and for its substantive work, which needs to fit the priorities of any supervising institution.