A new model for obtaining data protection consents: unbundling the proposed amendments to China's Personal Information Security Specification

On 1 February, 2019, the National Information Security Standardization Technical Committee issued an amended version of the GB/T 35372-2017 Information Technology – Personal Information Security Specification for public comment, with the period for making comments having closed on 3 March, 2019.

In common with the version currently in force (which was officially issued on 29 December, 2017 and took effect from 1 May, 2018 which we discussed in our earlier briefing here), the amended draft Specification would still be a "GB/T" national standard, i.e., recommended (but non-binding) national standard. However, given that the Draft Specification is the most comprehensive embodiment of China's personal information protection regime, its significance is its ability to influence Chinese regulators in terms of setting personal information protection benchmarks.

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