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ARTICLE · 27 DECEMBER 2024

PRC Guidelines On Identifying Sensitive Personal Information

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The PRC National Technical Committee 260 on Cybersecurity of SAC ("TC260") published new Guidelines on Identifying Sensitive Personal Information ("Guidelines")...

ChinaPrivacy
Gabriela Kennedy
Gabriela Kennedy
Joanna Wong
Joanna Wong
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The PRC National Technical Committee 260 on Cybersecurity of SAC ("TC260") published new Guidelines on Identifying Sensitive Personal Information ("Guidelines")1 on 18 September 2024,2 nearly three months after it released the draft guidelines ("Draft Guidelines") for public comment.3

Background

Under the Personal Information Protection Law ("PIPL"), data controllers are subject to more stringent requirements when processing sensitive personal information, such as more stringent protective standards, the requirement to obtain separate consent4 and to conduct privacy impact assessment ("PIA")5 before processing sensitive personal information. Data controllers processing sensitive personal information shall ensure that there is sufficient necessity in doing so, and are also required to inform data subjects of the necessity of processing the sensitive personal information and the associated impact on their rights and interests. Depending on the volume of

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