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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ DOMAIN · HEALTH & MEDICAL DATA

Health & Medical Data.

医疗健康数据

China's health- and medical-sector data regime — the sector-specific overlay on PIPL, the Data Security Law, and the Network Data Security Regulation governing how healthcare institutions, life-sciences companies, and digital-health providers handle patient and population data.

The health and medical sector sits under a dedicated layer of data rules stacked on top of China’s general data-protection regime. This domain collects the instruments that overseas pharma, medtech, hospital, and digital-health operators must layer onto PIPL, the Data Security Law, and the Network Data Security Regulation: the 2026 Measures for Data Security and Personal Information Protection of Healthcare Institutions, the national health and medical big-data measures, healthcare cybersecurity rules, the electronic-medical-record and population-health-information regimes, the Human Genetic Resources regulation and its implementing rules (with their cross-border choke points), real-world clinical-data guidance, and the foundational Basic Medical and Health Care and Health Promotion Law.

Patient health information is sensitive personal information under PIPL Article 28, so the consent, minimization, retention, and security baselines run higher in this sector than in most. Several instruments here also impose localization and access-control duties specific to medical institutions, and the genetic-resources regime adds an approval-and-security-review layer that has no general-regime equivalent.

§ LAWS IN THIS DOMAIN

The legal corpus.

32 laws.

§ BRIEFS

In this domain.

2 briefs.

  • § 01 · SPP

    Five Years of PIPL: The Supreme People's Procuratorate's Eight Typical Cases on Personal Information

    On November 2, 2026, the day after the fifth anniversary of the Personal Information Protection Law taking effect, the Supreme People's Procuratorate (SPP) issued eight typical cases on protecting citizens' personal information. Seven are prosecutions for the crime of infringing upon citizens' personal information (Criminal Law Article 253a); the eighth is a civil public-interest suit. DCC translates the SPP's release in full and maps the eight cases for counsel. Four points stand out. Information that is already public is 'not a public resource': compiling rental listings and selling them abroad, beyond the purpose for which they were posted, is the crime (Case 5). A passenger's upcoming flight is 'whereabouts and tracks' information, the most tightly protected criminal category (Case 6). Three of the eight leaks ran through people with legitimate access: insiders at source units, an airline's outsourced call-center agent, and bribed HR staff (Cases 1, 6, 7). And procuratorates now attach public-interest damages to PI crimes, set by sensitivity, scale, public value and cross-border risk rather than by what the offender earned: RMB 4 million against one recruitment-data seller (Case 7) and RMB 1.5 million against two people who scraped 3.86 million cancer-hospital records and moved them overseas, when their proven profit was RMB 10,800 (Case 8). The full notice and all eight cases are on the DCC law page.

    spp · supreme-peoples-procuratorate · typical-cases
  • § 02 · HEALTH-DATA

    China's Hospitals Get Their Own Data Rulebook: Reading the 2026 Healthcare Data Security & PI Measures

    On 12 February 2026 five agencies — the National Health Commission, the Ministry of Public Security, the Cyberspace Administration of China, the National Administration of Traditional Chinese Medicine, and the National Disease Control and Prevention Administration — jointly issued the Measures for the Administration of Data Security and Personal Information Protection of Healthcare Institutions (Trial). It is the first operational, sector-specific rulebook that turns the Data Security Law, PIPL, and the Network Data Security Regulation into concrete hospital obligations: a three-tier core/important/general data classification keyed to MLPS levels and commercial cryptography; a five-pillar full-lifecycle security system; a ten-item data prohibition list and an eight-item personal-information prohibition list; heightened protection for special groups; limits on facial recognition and AI; and a real enforcement chain running from named-person accountability through regulatory interviews, administrative penalties, civil tort liability, and criminal referral. DCC reads it for overseas pharma, medtech, and hospital-JV counsel — with the cross-border choke point and its academic-cooperation carve-out as the parts that most affect global clinical-data flows.

    health-data · healthcare · data-classification
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