Comments to TC260 on Internet Platform and Product Service Privacy Agreement Requirements (Draft for Comments)

2022-07-22 | Beijing

The European Chamber is pleased to have the opportunity to provide input on TC260’s draft Internet Platform and Product Service Privacy Agreement Requirements. Most articles of the Draft Requirement are clear and give a detailed explanation of a proper privacy agreement. However, some articles are difficult for data controllers with limited technical resources to follow. For example:

  • Requirements for Independent Consent under the Personal Information Protection Law (PIPL).  
  • Impact on User Interface/User Experience Design.  
  • Excessive Requirements on Disclosing Data Processing Activities.  
  • Sample Privacy Statement.  
  • Cookies.
  • The Requirement to Solicit Public Opinion for Changes in Privacy Policy May Not Work.