Abstract: The issue of how to safely and efficiently circulate and trade data has attracted so much attention that data gatekeepers have become a new type of participants in data security management. The paper systematically reviews the roles and responsibilities of traditional gatekeepers, and based on the combination of data element attributes and data element governance experience, clarifies that data gatekeepers’s main responsibility is to provide gatekeeping services in the processes of data resource utilization, data productization, data circulation and transactions. A further study that draws inspiration from the microkernel construction concept in the field of computer science finds that due to the diverse functions and types of data gatekeepers, they have different service objectives. To be specific, professional gatekeeping services are provided in the core modules of the kernel to protect multi-party rights, realize large scale data development and activate data market vitality, so that higher value and return can be gained from data; common gatekeeping services are provided in the peripheral modules of the kernel to ensure the orderly flow of data, so that data lifecycle management can be strengthened. At the same time, in order to empower the microkernel’s healthy development, service delivery capabilities should be improved in such a manner as to allow full play to data gatekeepers’ working together inter-complementally. At the national level, it is advised to further promote the construction of international certification standards for data gatekeepers, develop inventory management systems, design value co-creation schemes, and implement evidence-based evaluations of gatekeeper performance.

Key words: gatekeeper, data vendor, third party professional service, system framework, data element market ecology