Processes biometric data, in China

Cybersecurity Law of the People's Republic of China (as amended by the Decision of October 28, 2025), Art. 23 · Read the law's page

• This binds a network operator, meaning any organization that owns or manages a network or provides services over one, so it reaches every declared activity and every declared role; the level of protection follows the classification of the network under the classified protection system.
• Formulate internal security management rules and operating procedures, designate a person responsible for network security and put network security protection responsibility into effect (Article 23, item 1).
• Take technical measures against computer viruses, network attacks and network intrusions (Article 23, item 2).
• Monitor and record the network's operating status and security incidents and keep the network logs for not less than six months (Article 23, item 3).
• Take data classification, backup of important data and encryption measures (Article 23, item 4).

Arts. 8 and 13, Provisions on the Management of Network Product Security Vulnerabilities (Ministry of Industry and Information Technology, Cyberspace Administration of China and Ministry of Public Security) · Read the law's page

• Applies to a network operator, meaning the owner or manager of a network or a provider of services over one, so it reaches an app developer that runs its own servers or service (Articles 2 and 8).
• On finding or learning that your network, information system or equipment has a security vulnerability, take measures at once, verify the vulnerability in good time and complete its repair (Article 8).
• Keep a channel for receiving vulnerability information open and unobstructed, and keep the receipt logs for at least 6 months (Article 5).

Data Security Law of the People's Republic of China, Art. 27 · Read the law's page

• This binds any organization or individual engaging in a data-processing activity, regardless of sector, and reaches data generally rather than only personal information.
• Establish and maintain a full-process data-security management system covering the collection, storage, use, processing, transmission, provision, and disclosure of the data you process, and provide data-security education and training to your staff.
• Take the technical measures and other necessary measures appropriate to your processing to keep your data secure.
• Where you process data over the internet or another information network, meet this duty in addition to, not instead of, your classified-protection obligations under the Cybersecurity Law, already this jurisdiction's own deferred network-operator duty.
• If you process important data, an official classification this corpus cannot flag against on its own, designate a person responsible for data security and a managing body, and implement that responsibility.

Data Security Law of the People's Republic of China, Art. 29 · Read the law's page

• Strengthen risk monitoring of your data-processing activity, and on discovering a data-security defect, vulnerability, or other risk, immediately take remedial measures.
• On an actual data-security incident, immediately take disposal measures, promptly notify affected users as provided, and report the incident to the competent authority; the statute states no numeric deadline, only immediacy and promptness.
• This binds the same data processor as this jurisdiction's Data Security Law data-security-program duty; it adds a risk-monitoring and incident-response duty rather than reaching a different party.
• A processor of important data carries an additional, periodic risk-assessment-and-reporting duty under Article 30 tied to the important-data classification rather than to any activity in this vocabulary, so it is not flagged as its own instrument.

PIPL Arts. 28-32 · Read the law's page

• Obtain the individual's separate, explicit consent before processing any sensitive personal information, including a biometric identifier such as a faceprint or voiceprint, in addition to any general consent already collected.
• Notify the individual of the necessity of the processing and its impact on their rights before collecting sensitive personal information.
• Process biometric identifiers only for a specific, necessary purpose and under strict protective measures, and obtain guardian consent before processing a minor's data.
• No dedicated voiceprint statute exists as of this date; voiceprint is covered under this same sensitive-category duty rather than a separate biometric-specific rule.

Personal Information Protection Law of the People's Republic of China, Arts. 13(6), 27 · Read the law's page

• Confine processing of personal information someone has already made public to a reasonable scope tied to your stated purpose.
• Stop processing an individual's already-public personal information once they expressly decline, even though no prior consent was required.
• Obtain separate consent before any use of already-public personal information that would have a significant impact on the individual, including most AI-training uses.

Provisions on the Administration of Deep Synthesis Internet Information Services (互联网信息服务深度合成管理规定), issued by CAC, MIIT and MPS, 2022, Art. 10 · Read the law's page

• Strengthen your management of deep synthesis content: review your users' input data and synthesis output by technical or manual means, and record and retain the related network logs, if you provide a deep synthesis service.
• Build and maintain a feature database for identifying illegal and undesirable information, with entry standards, rules, and procedures.
• Upon discovering illegal or undesirable information, take disposal measures and preserve relevant records in accordance with law, and promptly report the discovery to the cyberspace administration department and the relevant competent authority. The text marks only this reporting step as prompt, counted from the moment of discovery, and states no separate promptness standard for the disposal and record-keeping steps that precede it.
• Separately take measures against the responsible user, such as warning, restricting features, suspending the service, or closing the account, in accordance with law and your service agreement.

Provisions on the Administration of Deep Synthesis Internet Information Services (互联网信息服务深度合成管理规定), issued by CAC, MIIT and MPS, 2022, Arts. 16-17 · Read the law's page

• Label content your service generates or edits, by a technical measure that does not interfere with normal use
• Apply a prominent public-facing label where the service simulates dialogue or writing, synthesizes or alters voice, generates or swaps faces, or builds immersive simulated scenes
• Retain the log information the Provisions require

Regulation on Network Data Security Management (State Council Order 790), Arts. 9-11 · Read the law's page

• Applies to a network data processor, meaning an individual or organization that decides for itself the purpose and means of processing network data, for processing in China (Articles 2 and 62); because that reaches almost any organization running a system, this instrument flags on every activity and role this corpus can express.
• Protect network data on the basis of classified cybersecurity protection: keep data security management rules in place and use encryption, backup, access control and security authentication (Article 9).
• On finding a security defect, vulnerability or similar risk in a network product or service you provide, take remedial measures at once, tell users as required and report to the competent department; where national security or the public interest is endangered, also report to the competent department within 24 hours (Article 10).
• Keep an emergency plan for network data security incidents; when an incident occurs, start the plan at once, act to stop the harm spreading and remove the hazard, and report to the competent department as provided (Article 11).
• Where an incident harms the lawful rights and interests of individuals or organizations, promptly tell those affected the incident, the risk, the harm and the remedial steps taken, by phone, text message, instant message, email or public announcement, unless a law or administrative regulation allows non-notification (Article 11).

人脸识别技术应用安全管理办法, issued jointly by the Cyberspace Administration of China and the Ministry of Public Security, signed 13 March 2025, effective 1 June 2025 · Read the law's page

• These duties bind the deployment and use of facial recognition; Article 2 exempts facial-recognition R&D and algorithm-training activities from the Measures. Obtain separate, explicit, informed, voluntary consent before collecting or using facial recognition data, with guardian consent for anyone under 14, and use the method with the least impact on individual rights available.
• Store captured facial information only on the recognition device itself; do not transmit it over the internet unless a legal exception applies or the individual has separately consented.
• Retain facial information no longer than the minimum time necessary for the stated purpose.
• Offer a non-facial-recognition verification alternative whenever one exists; do not make facial recognition the sole means of identity verification.
• Do not install facial recognition devices inside hotel rooms, public bathhouses, public changing rooms, or public restrooms.
• File with the provincial-level cyberspace administration once the stored facial-information count reaches 100,000 individuals.

Measures for the Administration of National Cybersecurity Incident Reporting (Cyberspace Administration of China, issued September 11, 2025), Arts. 2, 4, 5, 8, 9, 12, 14 · Read the law's page

• On discovering or becoming aware of a cybersecurity incident affecting your own operations, grade it against China's four-tier National Cybersecurity Incident Classification and Grading Guide (especially major, major, relatively major, ordinary), and report only where you grade it relatively major or above; an ordinary incident carries no report duty under this instrument.
• Where the incident involves critical information infrastructure, report to your sector's protection-work department and to the public security organ within 1 hour of discovering or becoming aware of the incident.
• Where you are a department of a central or state organ, or a directly affiliated unit of one, report to your own department's cyberspace affairs unit within 2 hours of discovering or becoming aware of the incident.for a public body
• Every other network operator must report to the cyberspace administration department of its own province within 4 hours of discovering or becoming aware of the incident.
• Where your industry carries its own reporting rule, also report as your industry's regulator requires, and report a suspected crime to the public security organ promptly.
• Where an organization or individual provides you network-security or system-operation-and-maintenance services under contract, require that provider by contract to promptly report to you any cybersecurity incident it discovers through monitoring, and to assist your own reporting under these Measures; this is the paragraph that reaches a cloud host, managed-security vendor, or AI operator serving you as its customer.
• Within 30 days of completing disposal of a relatively major incident or above, submit a summary report covering the incident's cause, your emergency response, the harm caused, accountability, remediation, and lessons learned, through the same channel you used for the original report.
• This binds a network operator, meaning the owner, manager, or network service provider of a network, that builds or operates a network, or provides a service through a network, inside China; because that reaches almost any organization running a system, this instrument flags on every activity and role this corpus can express rather than a narrower guess.
• A major or especially major incident additionally triggers an escalation between government bodies up to the national cyberspace administration after you report; that further escalation is not a step you perform yourself.
• Taking reasonable and necessary protective measures, disposing of the incident under your emergency plan, effectively reducing its impact and harm, and reporting it promptly as these Measures require can draw lighter treatment, or none at all, of the liability of your unit and its personnel for the incident.