If software decides or scores a person, PIPL ADM duties apply — a human rubber-stamp does not hide it.
PIPL requires handlers using automated decision-making to be transparent, fair and just, and not to apply unreasonable differential treatment in transaction prices. People can refuse marketing-style ADM and request an explanation. A PIA is a listed trigger. CAC algorithm and recommendation rules add filing and user-control overlays for public-facing engines — that is the algorithm-filing sibling, not this page. Scoring employees, pricing, credit-like decisions and content ranking can all be ADM. ‘A manager clicked approve’ is not a defence if the model made the real decision.
4 questions before you choose the route.
This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.
Is a person scored or decided about?
Credit, price, hire, content, ads.
UseIs it public-facing recommendation?
Then algorithm rules may also apply.
PublicHas a PIA been done?
ADM is a statutory PIA trigger.
PIACan the person refuse marketing ADM?
Opt-out and explanation path.
RightsWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Is a spreadsheet filter ADM?
If it automatically decides or scores people in a material way, treat it as in-scope. Trivial sorts are not the target; silent CV-ranking is.
Does algorithm filing replace the PIA?
No. Filing is a CAC public-algorithm overlay. PIA is the PIPL handler duty.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.