Employee Data Privacy

China - Security Requirements

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What security obligations are imposed on data controllers and data processors? 

Security requirements may not always be included in the data protection law, but are key to guaranteeing lawful processing of personal data. The entity processing the data must take all useful precautions with respect to the nature of the data and the risk presented by the processing, to preserve the security of the data and, prevent alteration, corruption or access by unauthorized third parties.

Appropriate technical and organizational measures should be implemented to ensure a level of security appropriate to the risk. China’s Personal Information Security Specification includes recommended security practices such as: data breach response plans; trainings; annual data breach drills; and, risk/security assessments prior to partnering with third party data processors and before transferring data internationally.

Under the Specification, sensitive personal information should include additional measures, such as encryption. In the event that personal biometric information is collected, the information should only be stored after technical processing to limit the data collection (ex., storing only a summary, or deleting an original image of the biometric information after usage). In addition, personal biometric identification information should be stored separately from the personal identification information.

In terms of personal data protection in the employment sector, the Regulation on Employment Service and Employment Management (2015 Amendment) (≪就业服务与就业管理规定(2015年修订)》) provides that employers must keep employee personal information confidential. Disclosing any employee's personal data to the public requires the employee's written consent.


HR Best Practices: Employers should take necessary measures to ensure the security of personal information, prevent leakage or loss of personal information and take remedial measures immediately when leakage or loss of information occurs. However, there is no explicit guidance in place regarding what "necessary measures" are required to ensure information security in the course of business.


UKG's HR Compliance Assist team relies on a network of internal and external compliance experts and lawyers to provide clients with best practices and recommendations on topics such as HR document retention, employee data privacy, and HR electronic records. HR Compliance Assist also provides local compliance monitoring and alert services in select countries where UKG's customers have employees. HR Compliance Assist is a service exclusively available to UKG customers.

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