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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · BLACK-GREY-MARKET

Filed under black-grey-market

Every brief tagged "black-grey-market".

  • § 01 · ENFORCEMENT

    公安部网安局 Publishes 10 Typical Cases of Infringing Citizens' Personal Information — Insiders, Order Decryption, and Article 253a in Practice

    On 11 August 2026 the MPS Cyber Security Bureau (公安部网安局) published ten typical cases (典型案例) of the crime of infringing upon citizens' personal information, brought under the Clean Net special campaign (净网专项行动). Across the batch: 123 suspects, more than 9.6 million items of personal information, and roughly 23.6 million yuan in case value. The striking feature is not the volume but the access route — in at least half the cases the data came out through someone with legitimate access: an employee, a planted hire, a service vendor, a hotel partner, or a school and hospital staffer. This DCC brief translates all ten fact patterns, sets them against Criminal Law Article 253a and the 2017 PI Criminal Interpretation thresholds, and draws out what the batch signals for companies whose exposure runs through their own staff and vendors.

    enforcement · criminal-liability · mps
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