



On November 1, 2021, the same day that the Personal Information Protection Law (PIPL) of People’s Republic of China had taken effect, the Ministry of Industry and Information Technology (MIIT) issued the Notice on Improving User Service Perception of Information Telecommunications (hereinafter referred to as “the Notice”). It lists out the critical tasks that MIIT has assigned to provide general service system and enhance user experience.
The tasks listed in the Notice are officially summarized as Operation 542, which consist of: optimizing service in five main fields; a requirement for certain enterprises to establish two lists for personal information protection; improving four service capabilities. Most of these assignments have specified both their quantitative goals and finishing dates.
Among these tasks, the “two lists” policy has attracted the most attention due to its involvement with top internet giants in China. The “two lists” refer to:
1. the list of personal information already collected (by the service/app)
2. the list of personal information shared with third party (by the service/app)
Such two lists are required to be published in the secondary menu of the app for users to check. These mandatory publishing contents require concision, and should include basic information as well impartial research scenarios of the collected information. The finish date of this task will be before December 2021.
Furthermore, MIIT released an annex along with the Notice to specify that the first batch of enterprises must implement the “two list” work, and the internet giants who own most of the well-known and widely used app in China are mentioned. The annex covers a variety of sectors from online shopping (JD, Taobao, Tmall), social media (weibo, Kuaishou, Tik Tok), instant communication (Wechat, DingDing), to transportation, online Q&A community and web browsers.
The issuing of the Notice almost killed the last possibility for local internet giants to find “grey zone” and keep their excessive, if not abusive use of user information in the dark. The short timeline would also undoubtedly lead to a series of busy compliance actions and technical updates within their apps. In the long run, by-the-book participants in the sector would benefit, regardless of local or foreign origin. This possible business model change in such giants forced by the “two list” would also result in fairer market competition. Such a situation may help some traditional companies or online SMEs in sectors such as transportation, catering, and shopping to get back some of the callously taken marketshare by the excessive algorithm and user profiling from the giant apps before.
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