Episode 6: Further Developments In PRC Data Privacy Regulations

An updated draft of China's Amended Personal Information Security Specification (Amended PIS Specification) and proposed new amendments to the privacy specification for mobile apps (App Privacy Specification) were published this week, alongside brand new draft privacy regulations for the banking sector. These drafts will, if implemented, introduce some significant changes to current data protection practices in China as follows:

1. Amended PIS Specification

• Bundled consent will be banned. Separate consent may now be required for each specific scope of collection (e.g. separate tick boxes for direct marketing), rather than an overarching consent.
• Mobile phone numbers are no longer deemed to be "sensitive personal information". On the other hand, contact lists on personal mobile devices are now deemed sensitive personal information.