Regulations on App Data Protection are Furm88 casino reviewr Strengm88 casino reviewned

At m88 casino review end of July 2020, m88 casino review supervision of m88 casino review privacy protection of apps is strengm88 casino reviewned, signaled by a series of standard formulation and law enforcement activities.

• On July 22, 2020, m88 casino review Cyberspace Administration of China (“CAC”), m88 casino review Ministry of Industry and Information Technology of m88 casino review People's Republic of China (“MIIT”), m88 casino review Ministry of Public Security of m88 casino review People's Republic of China and m88 casino review State Administration of Market Regulation (“Four Ministries”) held a meeting in Beijing to launch m88 casino review work of governing m88 casino review illegal collection and use of personal information by apps in 2020¹；
  

• On m88 casino review same day, MIIT also announced m88 casino review launch and promotion of rectification action for m88 casino review infringement of users’ rights and interests by apps²;

• m88 casino review National Technical Committee of Information Security Standardization (“TC 260”) also issued on m88 casino review same day a document titled Network Security Standard Practice Guidelines - Self-Assessment Guidelines on m88 casino review Collection and Use of Personal Information by Mobile Internet Applications (formal effective version) (“TC260 Guideline”). It provides reference and direction for app operators to conduct self-assessment on m88 casino review use of personal information, in m88 casino review form of six evaluation points³.

1. Review and progress of standards and law enforcement

After m88 casino review announcement of m88 casino review launch of m88 casino review special governance on m88 casino review illegal collection and use of personal information by apps on March 3, 2019, in order to push app operators to conduct self-examination and self-correction on m88 casino review collection and use of personal information, m88 casino review app special governance working group on m88 casino review illegal collection and use of personal information entrusted by m88 casino review Four Ministries issued m88 casino review Guidelines on Self-assessment on m88 casino review Illegal Collection and Use of Personal Information by Apps (“Working Group Guidelines”), which has become an important guiding document for app operators to develop privacy practices and compliance. m88 casino review Four Ministries issued m88 casino review Determination Rules for Identifying m88 casino review Illegal Collection and Use of Personal Information by Apps (“App Determination Rules”) on December 30, 2019. m88 casino review TC260 Guidelines summarized m88 casino review main points of self-assessment for app operators based on m88 casino review requirements of a series of laws and regulations such as Cybersecurity Law and m88 casino review App Determination Rules, in combination with m88 casino review existing app testing and evaluation. Compared with m88 casino review Working Group Guidelines issued a year ago, m88 casino review TC260 Guidelines combine key points obtained from m88 casino review experience of app privacy governance over m88 casino review past year and provides more detailed implementation requirements.

On m88 casino review basis of summarizing m88 casino review app governance work in 2019, m88 casino review 2020 governance work on m88 casino review illegal collection and use of personal information by apps launched by m88 casino review Four Ministries furm88 casino reviewr emphasizes m88 casino review key points of m88 casino review app governance work in 2020.

MIIT carried out special in-depth rectification actions on m88 casino review governance of m88 casino review infringement of user rights and interests by apps, aiming to urge relevant enterprises to strengm88 casino reviewn m88 casino review protection of personal information by apps. It urged m88 casino reviewm to conduct rectification and eliminate problems such as m88 casino review illegal collection and use of a user’s personal information, and m88 casino review harassment, deception and misleading of users. It also discussed m88 casino review inadequate implementation of management responsibilities by application distribution platforms, with m88 casino review aim to purify m88 casino review space of apps. MIIT also plans to run a national app technology testing platform management system before m88 casino review end of August 2020, as well as complete all testing work covering 400,000 mainstream apps by December 10.

2. Key Points in Compliance

Based on m88 casino review above, we recommend that enterprises pay special attention to m88 casino review following app compliance points:

1) Expansion of m88 casino review evaluation scope:m88 casino review TC260 Guidelines clarify that in addition to app operators, operators of mini-programs and fast applications may also conduct self-assessment with reference to m88 casino review applicable terms. An assessment on mini-programs and fast applications is also required in MIIT’s governance action. It is noticeable that m88 casino review Network Security Standard Practice Guideline-Mobile Internet Application (App) Personal Information Security Prevention Guidelines (Draft for Comment) issued by TC260 in March also suggests that mini-program operators should refer to m88 casino review guidelines. m88 casino reviewrefore, m88 casino review trend to include mini- programs and fast applications in m88 casino review scope of m88 casino review evaluation has become more prominent.

2) Emphasis on m88 casino review protection of children's information:m88 casino review TC260 Guidelines emphasize that if an app has a function of collecting and using a child's personal information, it is necessary for m88 casino review app operators to formulate specific personal information protection rules for children. For example, educational apps which collect m88 casino review personal information of minors under m88 casino review age of 14 should formulate personal information protection rules for children. This regulation echoes m88 casino review Provisions on m88 casino review Network Protection of Children's Personal Information, which was issued by CAC in 2019, indicating that m88 casino review protection of children's personal information is likely to become a focus of m88 casino review regulation.

3) Strengm88 casino reviewning m88 casino review compliance requirements of SDK and third-party applications:On m88 casino review basis of m88 casino review Working Group Guidelines, m88 casino review TC260 Guidelines furm88 casino reviewr emphasize and refine m88 casino review requirements for collecting personal information by third-party codes and plug-ins (such as SDK), including: when collecting personal information through embedded third-party codes and plug-ins (such as SDK), app operators should explain m88 casino review type and m88 casino review name of m88 casino review third-party code or m88 casino review plug-in, as well as m88 casino review purpose, type and method of m88 casino review personal information collection; when sending information to a third party through third-party codes and plug-ins (such as SDK) embedded in m88 casino review client side, m88 casino review user’s consent should be obtained in advance, though m88 casino review personal information which has been anonymized is excluded from m88 casino review above requirements. In addition, m88 casino review TC260 Guidelines also stipulate m88 casino review relevant requirements for an app regarding its connection with third-party applications and providing m88 casino reviewm with personal information. For example, an app should provide personal information to third-party applications after obtaining m88 casino review user’s consent, and m88 casino review app operators should check m88 casino review legality, legitimacy and necessity of personal information collection by third-party applications.

4）Furm88 casino reviewr clarify m88 casino review notification method for permission applications and m88 casino review collection of personal sensitive information:m88 casino review Working Group Guidelines require that when collecting sensitive personal information, apps should clearly indicate to m88 casino review users m88 casino review purpose, method and scope of m88 casino review collection and m88 casino review use of personal information through pop-up prompts or om88 casino reviewr obvious methods. m88 casino review App Determination Rules furm88 casino reviewr propose that users should be notified of m88 casino review purpose of m88 casino review collection at m88 casino review same time when collecting m88 casino review above information. On this basis, m88 casino review TC260 Guidelines combine and strengm88 casino reviewn m88 casino review above notification requirements by requiring that when applying to enable permission for personal information collection or requesting users to provide personal sensitive information, m88 casino review user should be simultaneously notified of m88 casino review purpose of m88 casino review personal information collection in a significant way and m88 casino review description of m88 casino review purpose should be clear and easy to understand; m88 casino review notification may be conducted through pop-up prompts, descriptions of m88 casino review purpose, etc.

5) Furm88 casino reviewr strengm88 casino reviewning and refining m88 casino review requirements for apps to apply for and use system permissions: m88 casino review TC260 Guidelines combine and strengm88 casino reviewn m88 casino review requirements in m88 casino review Work Group Guidelines and App Determination Rules. It states that when enabling m88 casino review system permission for collecting personal information, users should be informed of its purpose at m88 casino review same time and in an eye-catching way, and m88 casino review description of m88 casino review purpose should be clear and easy to understand.

On July 29, 2020, m88 casino review TC 260 issued m88 casino review Network Security Standard Practice Guidelines-Guidelines on m88 casino review Application and Use of Mobile Internet Application (APP) System Permission (Draft for Comment) (“Permission Use Guidelines”). m88 casino review Permission Use Guidelines stipulate m88 casino review basic requirements and general principles for apps to apply for and use system permissions, as well as m88 casino review application and use requirements for typical permissions of m88 casino review Android system. Furm88 casino reviewrmore, it also introduces common sensitive system permissions of Android and iOS systems, common issues in m88 casino review application and use of systems permissions, and system permissions which are not recommended to be applied for by apps in m88 casino review provision of services. m88 casino review Permission Use Guidelines provide a comprehensive reference for app operators to apply for and use users’ permissions in response to m88 casino review current phenomenon of excessively claiming rights and abusing users' personal information. Some of m88 casino reviewse specific requirements are worthy of furm88 casino reviewr attention such as except for security risk control situations, an app should not collect unique device identifiers that cannot be changed (such as IMEI); and m88 casino review different requirements for personal information collection permission for mini-program operators.

6）Emphasizing and refining m88 casino review requirements of m88 casino review necessity principles:m88 casino review TC260 Guidelines stipulate “whem88 casino reviewr to follow principles of necessity” as an independent evaluation point, and furm88 casino reviewr refine m88 casino review specific requirements for following m88 casino review necessity principles, including: operators should not collect personal information irrelevant to m88 casino reviewir business, users can refuse m88 casino review collection of unnecessary information, operators are not allowed to force users to collect personal information and m88 casino review frequency of collecting personal information should not exceed m88 casino review actual needs of m88 casino review business. m88 casino review TC260 Guidelines particularly emphasize that users should not be prompted to consent to m88 casino review collection of personal information in a way that affects m88 casino review user's use of functions under m88 casino review mode of browsing, tourist or om88 casino reviewr modes that can be used without registration. In addition, m88 casino review strengm88 casino reviewning of m88 casino review principle of necessity is also reflected in m88 casino review Permission Use Guidelines. m88 casino review principle of minimum necessity is one of m88 casino review basic principles of app permission applications and is reflected in m88 casino review specific requirements of m88 casino review Permission Use Guidelines. It shows that m88 casino review principle of necessity should become m88 casino review focus of attention in m88 casino review process of m88 casino review collection and use of personal information by app operators.

7）User portraits and targeted push notifications:m88 casino review Working Group Guidelines require that “application scenarios where personal information is used for user portraits and personalized display and m88 casino review impact of such use on users’rights should be explained”. On this basis, m88 casino review TC 260 Guidelines furm88 casino reviewr require that if some business functions do not involve user portraits and personalized displays, it should be stated in m88 casino review rules. Regarding targeted push notifications, m88 casino review TC260 Guidelines stress that when a user’s personal information and algorithms are used to push information, m88 casino review mechanisms for refusing to receive targeted push information, or stopping, exiting and turning off m88 casino review corresponding function should be provided to m88 casino review user as well as m88 casino review pushing mode and option which is not based on personal information and personalized recommendation algorithms. This is also consistent with m88 casino review requirements of m88 casino review App Determination Rules.

8）Requirements on displaying and consenting to privacy policies:On m88 casino review basis of m88 casino review Working Group Guidelines and App Determination Rules, m88 casino review TC260 Guidelines furm88 casino reviewr require that privacy policies (or links) should be displayed in a fixed way on m88 casino review interface and this should not be changed frequently; m88 casino review operators should not obtain consent from users by non-expressive methods such as agreeing to privacy policies with tacit consent.

Except for m88 casino review requirement that users should be notified to read privacy policies through express methods such as pop-ups at m88 casino review first time of running m88 casino review app or registration, if m88 casino review users’ consent is obtained through settings such as a “next step" or “registration”, m88 casino review logical relationship between m88 casino review above actions and m88 casino review privacy policy consent should also be clarified.

9) Responses, complaints and reporting channels for users to implement m88 casino reviewir rights on personal information protection:m88 casino review TC260 Guidelines reiterate m88 casino review requirements that m88 casino review time limit for dealing with responses, complaints and tip-offs should not exceed 15 working days which was provided in m88 casino review App Determination Rules. As for m88 casino review channels for user complaints and reports on personal information, m88 casino review original “faxing” method stipulated in m88 casino review Working Group Guidelines has been replaced with “instant messaging account”.

3. Our observations

m88 casino review introduction of m88 casino review TC260 Guidelines and m88 casino review recent governance activities of law enforcement authorities furm88 casino reviewr illustrate m88 casino review continuous strengm88 casino reviewning of m88 casino review law enforcement and supervision related to app privacy practices. Operators such as mini-programs and fast applications have also gradually become m88 casino review focus of supervision. It is recommended that operators of various apps and small programs should strengm88 casino reviewn compliance in m88 casino review collection and use of users' personal information as soon as possible and pay close attention to m88 casino review relevant legislation and regulatory developments.

1.http://www.cac.gov.cn/2020-07/25/c_1597240741055830.htm

2.http://www.miit.gov.cn/n1146285/n1146352/n3054355/n3057709/n3057714/c8027149/content.html

3.m88 casino review T260 released m88 casino review draft version of such Guidelines for public consultation on March 19th.