On August 22, 2019, the Cyberspace Administration of China
("CAC") promulgated the Regulation on
Cyber Protection of Children's Personal Information
("Regulation"), which will take effect
on October 1, 2019. As the first regulation in China specifically
regulating children's personal information ("PI"), it
sets the age of a child for online privacy purposes and stipulates
the online activities to be regulated by setting out several
requirements that Network Operator (defined below) must follow.
Definition of "child" and activities to be
regulated
Definition of "child":
Different countries have their own age threshold when defining a
child for online privacy protection purposes determined by factors
like cultural differences and the context of a particular
legislative scope. For example, the USA's Children's Online
Privacy Protection Act ("COPPA") sets
the age at 13, whereas the EU's General Data Protection Rules
("GDPR") sets the age at 16 and allows
EU members