Llinks partner, Dr. David Pan and senior associate Ms. Susan Deng, have been selected to spearhead the drafters of the 'Compliance Guidelines for Generative Artificial Intelligence Data Application' (T/CECC 027-2024) group standard. Their deep expertise in cybersecurity, data privacy, and AI compliance positions them as key contributors to this critical industry framework. The standard is being developed under the auspices of the CECC.

Link: https://www.ttbz.org.cn/Home/Show/74010

The Guidelines (T/CECC 027-2024) was officially released on April 16, 2024, and implemented on May 1, 2024. Developed under the leadership of the National Industrial Information Security Development Research Center (First Institute of Electronics of the Ministry of Industry and Information Technology), managed by the China Electronic Chamber of Commerce (CECC), and organized by the Intelligeast Standards Center.

The Guidelines establish a robust framework for generative AI data compliance, outlining specific requirements for each phase of the data lifecycle. From data collection and labeling to model training, testing, and content generation, the standard provides detailed guidance. By comprehensively addressing the entire AIGC data journey, it fills a crucial void in the current regulatory environment.

David Pan, Partner

Dr. David Pan is the partner-in-charge of the Corporate Compliance Practice Group of Llinks Law Offices. Dr. Pan obtained his LL.M. from Harvard Law School, and his Doctor of Jurisprudence from Shanghai Jiao Tong University. Dr. Pan was admitted to practice law in 2002. He is also admitted in New York State, USA.

Dr. David Pan has practiced law in China and in the U.S. over 20 years. He accumulated an in-depth knowledge on Chinese and international business culture and legal systems. Prior to joining Llinks, Dr. Pan worked in two well-known Chinese law firms, and most recently worked for a Fortune 500 Company as its General Counsel for Greater China. In addition to his corporate services such as mergers and acquisitions, joint venture, technology license etc., Dr. Pan specializes in various compliance matters including anti-trust, anti-corruption, cybersecurity and data protection, export control and sanctions. The clients that he represented spread over various industries, including auto, investment, energy, life science and health, chemical, pharmaceutical, the Internet, food, manufacturing, sports and entertainment, retail and consumer, real estate.

Based on his thorough understanding on business operations, Dr. Pan also specializes in providing companies with practical solution-oriented services in the regulatory compliance areas of anti-corruption, antitrust, and anti-unfair competition. Dr. Pan has a distinguished track record advising leading automotive, manufacturing, and retail clients on a wide range of competition and compliance matters. His expertise spans policy development and implementation, internal investigations, crisis management, and third-party risk assessment. Renowned for his work in this area, Dr. Pan has been consistently recognized by Chambers & Partners, The Legal 500, LEGALBAND, and Who's Who Legal.

Beyond traditional compliance, Dr. Pan has been at the forefront of advising clients on complex data-related challenges, including offshore data management, data governance, privacy compliance, and cybersecurity. With a proven track record of success, Dr. Pan has led his team in developing and enhancing data compliance frameworks for over 100 enterprises across diverse industries. This extensive experience has positioned Dr. Pan as a leading authority in cybersecurity and data protection. His exceptional work has been consistently recognized by industry-leading publications such as LEGALBAND, Chambers & Partners , The Legal 500, and ALB, including being named a 'Leading Lawyer in Data Privacy Protection in Asia' by ALB.

Dr. Pan acts as an adjunct professor in Law School of Shanghai Jiao Tong University, an examiner expert of Shanghai United Assets and Equity Exchange and a third-party supervision specialist for Shanghai FTZ's 'Compliance without Prosecution Pilot Program'.

Susan Deng, Senior Associate

Ms. Susan Deng graduated from East China University of Political Science and Law with a Bachelor's degree in Law and subsequently earned a Master's degree in Law, specializing in International Business Law, from the London School of Economics and Political Science. She is licensed to practice law in China.

Since 2017, Ms. Deng has focused on cybersecurity and data compliance. She is adept at developing practical compliance solutions for domestic and international companies operating in the digital marketing landscape. Her expertise encompasses the entire lifecycle of customer personal information, from collection to destruction. Ms. Deng has served a diverse clientele across industries such as medical devices, pharmaceuticals, e-commerce, multimedia, mobile internet, financial technology, hospitality, industrial manufacturing, FMCG, luxury goods, food, automotive, logistics, chemicals, and digital marketing. Moreover, she has provided legal counsel for emerging business models including IoT applications, NFT projects, private traffic operations, and MOI data tagging.

Leveraging her extensive experience, Ms. Deng delivers pragmatic and cost-effective solutions that align with regulatory mandates. She specializes in guiding traditional internet enterprises and clients in e-commerce, pharmaceuticals, manufacturing, and consumer goods through their digital transformation journeys, providing comprehensive legal services include:

Cybersecurity and data compliance assessments

Cybersecurity and data compliance frameworks for financing scenarios.

Digital marketing program compliance evaluations

Data security and privacy system development

Personal information security impact assessments

Human genetic resources compliance

Outbound data compliance analysis

Cybersecurity audits

Critical information infrastructure screening

Cybersecurity incident response planning and management