Impact of PIPL on Employment Relationships

The Personal Information Protection Law (“PIPL”) of the People’s Republic of China (“PRC”) was adopted at the 30th Session of the Standing Committee of the 13th National People’s Congress of the PRC on August 20, 2021. It was promulgated the same day through Presidential Decree No. 91. The PIPL will become effective as of November 1, 2021.

Since in the course of employment employers can independently determine the purpose and method of processing (potential, current and former) employees’ personal information (e.g. name, gender, ethnicity, date and place of birth, ID No., address, email account, phone No., general health conditions, educational background, work experience, emergency contacts), employers are personal information processors in terms of PIPL.

Below we summarize some major issues under the PIPL that could have an impact on dealing with employment relationships.

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Impact of PIPL on Employment Relationships