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ARTICLE · 23 DECEMBER 2020

Back To Business Guide – Privacy

Do the Cybersecurity Law, and related guidelines, including Personal Information Security Specification remain applicable during the business resumption period?

ChinaCoronavirus (COVID-19)

Back to business FAQs

1. Do the Cybersecurity Law, and related guidelines, including Personal Information Security Specification remain applicable during the business resumption period?

Yes, organizations should continue, as far as possible, to comply with relevant data protection laws. This said, there are circumstances in which, given the current situation, entities (in particular government and healthcare bodies) may not need to full comply with all privacy obligations in the context of COVID- 19 prevention and control.

2. Is consent still required to collect personal information in the context of COVID-19 prevention and control?

Yes, however organizations should first check to see whether they have already obtained sufficient consent from their employees at onboarding (for example, many organizations set out in their standard employee privacy notices/ contracts that personal information may be collected for health control reasons). As noted above, certain

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