EXIN PIPL Foundation key terms
EXIN PIPL Foundation · Get comfortable with the vocabulary.
- Personal Information (个人信息)
- Related: Anonymization, Personal Information Subject, Sensitive Personal Information
Any information relating to an identified or identifiable natural person, recorded electronically or otherwise, excluding anonymized information. Examples include names, ID numbers, biometric data, location, and account records.
- Personal Information Subject (个人信息主体)
- Related: Personal Information, Individual Rights, Deceased Persons' Information
The natural person to whom personal information relates and whose rights the law protects. Only living individuals can be subjects; organizations, deceased persons, and anonymized datasets fall outside this concept.
- Personal Information Processor (个人信息处理者)
- Related: Entrusted Processing, Personal Information Processing, Personal Information Protection Officer
An organization or individual that independently determines the purpose and means of personal information processing. This is the core regulated entity that bears the main compliance obligations under the law.
- Personal Information Processing (个人信息处理)
- Related: Personal Information Processor, Automated Decision-Making, Deletion
Any operation performed on personal information, including collection, storage, use, processing, transmission, provision, disclosure, deletion, and other activities. The definition is intentionally broad to cover the full data lifecycle.
- Sensitive Personal Information (敏感个人信息)
- Related: Separate Consent, Personal Information Protection Impact Assessment, Minor's Personal Information
Personal information that, once leaked or misused, easily leads to harm to personal dignity or property safety. It includes biometric, religious belief, specific identity, medical health, financial account, and location tracking data, plus information of minors under fourteen.
- Anonymization (匿名化)
- Related: De-identification, Personal Information
Processing personal information so that it cannot identify a specific natural person and cannot be restored. Anonymized information is outside the law's scope, unlike de-identified information, which remains personal information.
- De-identification (去标识化)
- Related: Anonymization, Personal Information
Processing personal information so that it cannot identify a specific natural person without additional information. De-identified data remains personal information and stays subject to the law if it can be re-linked.
- Separate Consent (单独同意)
- Related: Consent, Sensitive Personal Information, Cross-Border Transfer
A distinct, standalone indication of agreement obtained for specific higher-risk processing activities, such as sensitive information, external provision, public disclosure, and cross-border transfer. It must be separated from general privacy notices rather than bundled into them.
- Consent (同意)
- Related: Separate Consent, Withdrawal of Consent, Legal Bases for Processing
A voluntary, explicit expression of intent by the subject, made with full knowledge, permitting processing of their personal information. Consent must be freely given and can be withdrawn at any time.
- Withdrawal of Consent (撤回同意)
- Related: Consent, Individual Rights
The subject's right to revoke previously given consent at any time. The processor must provide an easy withdrawal mechanism, and withdrawal does not affect the lawfulness of prior processing.
- Legal Bases for Processing (合法性基础)
- Related: Consent, Contract Necessity, Statutory Duty
The grounds that make processing lawful, such as consent, contract necessity, statutory duty, public health emergencies, public interest reporting, and other laws. Processing without at least one basis is unlawful.
- Contract Necessity (订立、履行合同所必需)
- Related: Legal Bases for Processing, Consent
A legal basis allowing processing needed to conclude or perform a contract to which the subject is a party, or to conduct human resources management under lawful labor rules and collective contracts.
- Statutory Duty (履行法定职责或义务)
- Related: Legal Bases for Processing, Public Interest
A legal basis permitting processing necessary to perform statutory duties or obligations, such as responding to lawful requests from regulators or complying with anti-money-laundering rules.
- Public Interest (为公共利益实施新闻报道、舆论监督)
- Related: Legal Bases for Processing, Statutory Duty
A legal basis allowing processing within a reasonable scope for news reporting or public opinion supervision in the public interest. Processing beyond a reasonable scope requires another basis such as consent.
- Individual Rights (个人权利)
- Related: Right to Know and Decide, Right to Access and Copy, Right to Deletion
The set of entitlements granted to personal information subjects, including rights to know, decide, access, copy, correct, delete, withdraw consent, and request explanation of processing rules.
- Right to Know and Decide (知情权、决定权)
- Related: Individual Rights, Privacy Notice
The subject's right to be informed about how their information is processed and to decide whether and how it may be handled, including restricting or refusing processing, except where laws provide otherwise.
- Right to Access and Copy (查阅、复制权)
- Related: Individual Rights, Right to Data Portability
The subject's right to inspect and obtain a copy of their personal information from the processor. Requests must be handled promptly and without unreasonable obstruction.
- Right to Correction (更正、补充权)
- Related: Individual Rights, Right to Deletion
The subject's right to have inaccurate or incomplete personal information corrected or supplemented. Processors must verify and update records upon a valid request.
- Right to Deletion (删除权)
- Related: Deletion, Individual Rights, Right to Correction
The subject's right to require deletion of their information when the processing purpose is achieved, a service stops, consent is withdrawn, processing is unlawful, or another statutory condition applies.
- Right to Explanation (要求解释说明权)
- Related: Individual Rights, Automated Decision-Making
The subject's right to demand an explanation of the processor's personal information processing rules. This supports transparency and accountability in automated and complex processing.
- Right to Data Portability (可携带权)
- Related: Right to Access and Copy, Individual Rights
The subject's right to obtain their personal information in a structured, commonly used, machine-readable format and to request transfer to another processor meeting regulatory conditions.
- Deceased Persons' Information (死者个人信息)
- Related: Personal Information Subject, Individual Rights
Information of a deceased person that close relatives may access, copy, correct, or delete for their own lawful and legitimate interests, unless the deceased arranged otherwise before death.
- Complaint and Report (投诉、举报)
- Related: Individual Rights, Regulator
The subject's avenue to report unlawful processing to the authorities, who must handle complaints promptly. Processors may also be required to accept and respond to complaints internally.
- Privacy Notice (告知义务)
- Related: Right to Know and Decide, Consent, Transparency
The duty to inform subjects, before processing, of the processor's identity, purposes, methods, categories, retention period, and how to exercise rights. Changes in purpose or method require re-notification.
- Entrusted Processing (委托处理)
- Related: Personal Information Processor, Joint Processing, Processor Obligations
Arrangement where a processor engages another party to handle personal information on its behalf. The processor must agree on purpose, period, and safeguards, and supervise the entrusted party, retaining liability.
- Joint Processing (共同处理)
- Related: Entrusted Processing, Personal Information Processor
Two or more processors jointly determining purpose and means of processing. They must agree on respective rights and obligations, and are jointly liable to the subject for harm caused.
- Cross-Border Transfer (跨境提供)
- Related: Separate Consent, Personal Information Protection Impact Assessment, Standard Contract
Providing personal information to entities outside mainland China. It requires a legal gateway such as security assessment, certification, standard contract, or another permitted path, plus separate consent and impact assessment.
- Standard Contract (标准合同)
- Related: Cross-Border Transfer, Security Assessment
A prescribed contractual template filed with the regulator as a cross-border transfer mechanism. It must reflect the required clauses and be filed before the transfer begins.
- Security Assessment (安全评估)
- Related: Cross-Border Transfer, Standard Contract
A regulatory review required for certain cross-border transfers, such as large-volume transfers or data held by critical information infrastructure operators. It must be passed before transfer occurs.
- Personal Information Protection Impact Assessment (个人信息保护影响评估)
- Related: Sensitive Personal Information, Cross-Border Transfer, Accountability
A documented pre-processing assessment required for sensitive information, automated decision-making, entrusted or joint processing, external provision, public disclosure, and cross-border transfer. Records must be kept for at least three years.
- Automated Decision-Making (自动化决策)
- Related: Right to Explanation, Personal Information Protection Impact Assessment
Using computer programs to automatically analyze or evaluate personal information and make decisions. It must be transparent and fair, and users must be offered an option not targeting personal characteristics or a convenient refusal.
- Minor's Personal Information (不满十四周岁未成年人个人信息)
- Related: Sensitive Personal Information, Separate Consent
Information of children under fourteen, treated as sensitive personal information. Processing requires guardian consent and dedicated processing rules.
- Personal Information Protection Officer (个人信息保护负责人)
- Related: Personal Information Processor, Accountability
A designated individual responsible for supervising processing activities and compliance, required for processors exceeding a regulatory volume threshold. Contact details must be filed with the regulator.
- Accountability (问责)
- Related: Personal Information Protection Impact Assessment, Regulator, Personal Information Protection Officer
The principle that processors must be able to demonstrate compliance through policies, records, training, and assessments. It underpins audits, documentation duties, and regulatory cooperation.
- Regulator (履行个人信息保护职责的部门)
- Related: Accountability, Complaint and Report, Penalties
Government departments such as cyberspace, market regulation, and public security authorities that supervise processing, investigate violations, and impose penalties. They may conduct inspections and require corrective action.
- Penalties (法律责任)
- Related: Regulator, Accountability
Sanctions for violations, including warnings, fines, suspension, and business license revocation for serious breaches. Individuals directly responsible may also face fines and personal liability.
- Transparency (公开透明原则)
- Related: Privacy Notice, Right to Explanation
The principle that processing purposes, methods, and rules must be clear, open, and disclosed to subjects. It supports informed consent and the right to explanation.
- Data Breach Notification (泄露通知)
- Related: Accountability, Regulator
The duty to notify the regulator and affected subjects promptly when a leak, tampering, or loss occurs. Notification must describe likely harm and remedial measures taken.