New Guidance Released to Clarify Identification Rules for SPI
2024
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Author: Yingying Zhu, Partner at BEIJING MINGDUN LAW FIRMEmail: zhu.yingying@mdlaw.cnDate: October 12, 2024 IntroductionUnder the Personal Information Protection Law of the People’s Republic of China (the “PIPL”), “sensitive personal information” (the “SPI”) is defined as “the kind of ‘personal information’ (the “PI”) that the leakage or illegal use of which could easily lead to the violation of personal dignity of data subject or harm to the data subject’s personal or property safety, including, but not limited to, information on biometric identification, religious beliefs, specific identity, health care, financial accounts, and personal whereabouts, etc., and the PI of minors under the age of fourteen1.” Only PI handlers2 with a specific purpose and sufficient necessity may process SPI, and strict protection measures should be taken to safeguard the SPI. The PIPL also requires that a data...