Shaping a data economy

Ms. Dinh Thi Thuy, Vice Chairwoman of the Board of Directors, MISA Joint Stock Company, and Deputy Secretary-General, National Data Association

The Law on Data 2024 provides the first legal foundation for recognizing property rights over data, as the government sets forth a strategy to mobilize all resources to enrich and elevate data as a national asset. It simultaneously delineates the responsibilities of regulatory authorities, platform operators, and data subjects.

The unification of standards for building, connecting, exploiting, and protecting data at the statutory level, along with the authorization for the establishment of data exchanges operated by licensed public service units or State-owned enterprises (SOEs), creates a secure framework for data circulation. This reduces data fragmentation, enhances trust in data sharing and reuse, and accelerates data commercialization.

In principle, data may be considered a tradable asset if ownership is clearly established, the transaction does not violate legal prohibitions, and, where personal data is concerned, consent from the data subject is obtained.

In terms of market trends, the most valuable datasets for exchange are those that serve business analytics, operational optimization, and the development of AI models. These include anonymized consumer behavior data, supply chain and logistics data, sensor data from smart agriculture and manufacturing, market trend information, and open government data.

To ensure safe data utilization while advancing the digital economy, Vietnam should initially implement a model in which the government retains control over core infrastructure, applying strict ex-ante and ex-post checks. Under this framework, an SOE or public service unit manages the platform and licensing, while businesses are permitted to list datasets and offer analytical products within the same ecosystem.

From a strategic AI perspective, MISA is investing heavily in developing an AI ecosystem, centered on our MISA AVA (Advanced Virtual Assistant) and integrated within the MISA AMIS (an all-in-one business management platform). To enable deep learning, enhance accuracy, and personalize the user experience, we seek diverse external data sources, from finance and accounting to retail, logistics, manufacturing, and human resources (HR).

In this context, data exchanges present a golden opportunity for MISA and other tech enterprises. Instead of spending significant time and resources collecting and cleaning fragmented data, we can swiftly access anonymized, non-personal datasets with clearly defined ownership under the Law on Data 2024, while strictly adhering to privacy rules.

Participation in the data exchange platform will not only shorten development cycles and reduce acquisition costs but also open cross-sector collaboration opportunities - extending the AVA’s application into new scenarios, from accounting automation to enhancing the customer experience. Additionally, as a data partner with strong data processing capabilities, we are also prepared to contribute anonymized datasets collected internally, in full compliance with the Law on Data 2024. In doing so, we hope to help cultivate a healthy and sustainable data-sharing ecosystem for all participating businesses.

 Mr. Huy Nguyen, CEO, Phygital Labs

Including the formalization of a data exchange platform, the Law on Data 2024 marks a turning point in the development of Vietnam’s data market. In the past, data was scattered, lacked standardization, and had unclear provenance. Now, we have a clear legal framework that defines ownership rights, usage rights, and responsibilities related to data. This not only improves the ability to responsibly harness data but also promotes the formation of a transparent and controlled data value chain, from collection and processing to analysis and commercialization.

Data becomes a commodity when it meets three conditions: it is reusable, it holds contextual value, and its origin can be verified. In my view, aggregated, anonymized, and processed datasets - such as consumer data, online behavior data, telecom data, business operations data, or sensor data from IoT (Internet of Things) devices - are among the first types of data that should be traded on exchanges.

At this stage, datasets with high readiness and clear application potential, such as retail data, financial data, logistics data, digital real estate data, and advertising data, are expected to have the highest trading volume. These types of data are already being widely used in market analysis, behavior prediction, and service personalization.

We should aim for a hybrid model where the government is responsible for developing the legal framework, setting technical standards, and ensuring privacy and cybersecurity, while technology enterprises operate the platforms, provide trading tools, handle data distribution, and offer data insurance. The platform should integrate blockchain technology to enable transaction traceability, provide tools to evaluate the credibility of data providers, and maintain data audit systems to strengthen market trust. This model protects the interests of users, businesses, and government agencies while encouraging innovation and sustainable data commercialization.

At Phygital Labs - a pioneer in physical-digital technology - we are developing digital identity platforms to enable the creation of digital assets. The operation of the data exchange not only allows us to access valuable data but also supports our goal of establishing identity and data standardization at the level of individuals, organizations, and devices. This is the foundation for building digital assets that are transparent, verifiable, and tradeable.

The platform will also foster an ecosystem that supports our solutions such as identity wallets, authentication infrastructure, and digital asset management systems. In the long term, it will help shape a data economy in Vietnam, where data is not only better protected but also recognized as a measurable, tradable, and income-generating asset.

Mr. Ngo Minh Quan, Chief Digital Officer, Rikkeisoft

Containing key provisions on the establishment of data exchanges, the Law on Data 2024 will officially take effect on July 1, 2025. This law plays a pivotal role in how data is utilized, developed, and protected in Vietnam.

First, it provides a transparent legal framework that standardizes the collection, processing, sharing, and trading of data. This helps foster the growth of the data market and maximize the value of data as a core resource for the digital economy.

Second, the law encourages individuals, businesses, and organizations to generate, enrich, and enhance the quality of data, which will strongly support research and innovation.

Third, it strengthens data protection by introducing strict regulations on personal data, privacy, sensitive information, and risk management. This builds greater information security in the digital environment and fosters trust among users and enterprises.

In terms of what types of data should be tradable, it should be data with clear economic value and potential to generate added value, while meeting legal requirements and having verifiable origin and quality. It must also have clearly defined ownership and usage rights, be standardized, secure, privacy-compliant, and have access control mechanisms.

Relevant data types may include public datasets released by government bodies and research institutions, such as macro-economic indicators, industry statistics, administrative maps, or scientific data. Non-personally identifiable data collected from IoT (Internet of Things) sensors, such as environmental or machine operation data, or anonymized and aggregated datasets like census results, demographic surveys, market studies, and spending behavior data, may also be eligible for lawful trading.

To ensure the data exchange platform is both efficient and protective of stakeholders’ interests, Vietnam should consider a phased and adaptive operational model. In the pilot phase, the government should lead the establishment and management of core foundations, including the legal framework, technical infrastructure, and common standards. A State-managed exchange platform could be launched first, focusing on public and aggregated government-collected data such as population, taxation, market, business, and trade data.

Once the pilot proves effective and the framework is complete, private sector and market participation should be encouraged. The model could then transition to a decentralized or hybrid form, allowing multiple specialized exchanges and data intermediaries to operate legally, thereby enabling broader data sharing and trading. A more open data market will support innovation, research, and application development across industries.

As a provider of digital transformation consulting and solutions, Rikkeisoft sees tremendous potential in the launch of the data exchange. It will become a rich and lawful resource that enhances the quality and precision of our solutions, especially in areas like machine learning and AI, where high-quality data is essential. It will also reduce costs related to data collection and cleansing, while enabling the creation of new solutions in emerging sectors such as finance, manufacturing, logistics, and consumer services.

Accessing market data through the exchange will also provide fresh insights, strengthen our competitive edge, and open up new partnership opportunities for Rikkeisoft in Vietnam’s digital data ecosystem.

Ms. Mai Thi Thanh Oanh, Head of Sales, Coc Coc

Effective from July 1, the Law on Data 2024 affirms the role of data as a national resource and a driver of comprehensive development, and includes the establishment of data exchanges and data-based products. This marks a significant step in reshaping how data is governed and utilized in Vietnam. The Law provides a unified legal framework to ensure that data is accessed, processed, and shared in a lawful, efficient, and secure manner, enabling businesses to confidently invest in local data infrastructure under the “Made in Vietnam” strategy for national digital transformation.

It emphasizes the principles of transparency, security, efficiency, simplicity, and convenience in data use (Article 5), and requires the setup of systems to detect risks related to privacy, cybersecurity, and access control (Article 25). These form the foundation for a secure and trustworthy data exchange.

The Law’s direction is aligned with Resolution No. 57 from the Politburo, which recognizes data as a core input for science, technology, and innovation. Within this legal framework, the creation of a data exchange can help build a national data ecosystem that is safe, competitive, and innovative, with the State playing a regulatory role, businesses contributing expertise, and individuals having their rights protected.

Treating data as a commodity for exchange should be based on three key principles: commercial value, reusability, and legal clarity. Not all data is suitable for trading. Sensitive, unprocessed, or unverified data must be strictly controlled to prevent privacy breaches and security risks.

Suitable types of tradeable data include non-personal data such as weather, geographic, market price, and environmental data; anonymized behavioral data such as clickstream patterns, purchasing history, or app interactions; and aggregated data on markets, industries, and consumer trends. In today’s context, consumer data, anonymized financial data, and supply chain datasets are among the most in-demand, serving as vital inputs for AI models, marketing strategies, market forecasts, and risk analysis. If exchanged transparently and in line with legal safeguards, this data can act as “clean energy” for the digital economy.

Globally, various models of data exchanges have emerged - centralized, decentralized, or vertical-sector platforms. Each has strengths and limitations, and the choice of model in Vietnam should depend on data demand, governance capacity, and the required levels of transparency and security.

Politburo Resolution No. 68 positions private-sector technology enterprises as key drivers of the economy. From a business perspective, I think this model will work: the government sets policies, legal standards, and ensures oversight, while domestic tech firms deliver the infrastructure, analytics, and operational expertise.

To ensure secure and efficient operations, the exchange should adopt advanced technologies - blockchain for data authentication, AI for analysis, digital contracts and e-signatures for transactions, and a transparent trust scoring system with clear evaluation criteria such as transaction history, data quality, and user feedback. This will strengthen trust and accountability across the ecosystem.

When each stakeholder plays its part, the data exchange can become a core component of Vietnam’s digital infrastructure - fueling economic growth, improving competitiveness, and safeguarding national data sovereignty.

As a platform offering web browsing, search, and online advertising, Coc Coc sees the exchange as a transformative opportunity, especially as AI adoption accelerates across industries. Effective AI requires diverse, high-quality data that reflects real user behavior and needs. But the use of such data must strictly respect privacy and legal standards.

Mr. Truong Duc Luong, Chairman, Vietnam Security Network (VSEC)

Until now, data has only been recognized as an asset in qualitative terms. It is easy for people to say that data is valuable, but there have been few practical methods to quantify that value. As a result, data has often been shared and used widely, both formally and informally, with prices that are inconsistent and not based on any clear formula.

The introduction of the Law on Data 2024 helps establish a formal market for the buying, selling, and sharing of data, enabling better social governance and tax management. In particular, the data exchange plays a crucial role. Its official presence helps shape a transparent and healthy data marketplace, while encouraging responsible data use and sharing, protecting private data, and raising public awareness.

There are two main types of data: raw data and processed data. Only processed data should be traded on a data exchange. Raw data includes details like name, date of birth, workplace, and company revenue. Processed data refers to insights such as trend analysis, customer demand forecasting, or detailed land use statistics. For raw data to be traded, the consent of the data owner is required. If this is not properly enforced, it may expose both the seller and buyer to legal risks.

Economically, processed data tends to offer greater value because the information it contains can generate clearer economic benefits and provide more differentiated utility for the buyer. Currently, the most frequently traded types of processed data include insights into consumer behavior in finance, food and beverages, health, and personal spending.

According to the government’s current directions, the State will manage and operate the data exchange. Data pricing will depend on the data type: public data will be priced by the State, while private data can be priced independently by the user, provided it complies with legal requirements on data protection and sharing.

In addition to the three core components of a data exchange - the operator, data sellers, and data buyers - there will also be supporting entities involved in compliance oversight. These may include organizations responsible for verifying that all data on the platform is legal. Enterprises may also participate in this and carry out data evaluation tasks.

A key element is ensuring cybersecurity, protecting the data on the exchange from unauthorized breaches. This responsibility should be assigned to a designated party, either internal or an official partner of the exchange operator. That party should operate transparently and be selected based on their capacity to provide robust cybersecurity from the outset, including system and service design, appropriate technology selection, and the qualifications of the operating personnel.

With the regulatory framework set by the Law on Data, the Law on Personal Data Protection, and related decrees, the operation of the data exchange will raise awareness among individuals and businesses about data protection and usage. This will also stimulate demand for cybersecurity services - such as compliance checks for data storage, processing, and delivery - and for assessments of the cybersecurity readiness of businesses participating in the exchange, ensuring they do not pose systemic risks to the platform. There are also many other areas where the data market is likely to have a positive impact.