WHAT 委托处理 MEANS
What 委托处理 means
The handler and entrusted party should agree the purpose, period, method, categories, protection measures and rights / obligations. The entrusted party must act within the mandate and is restricted from sub-entrusting without consent.
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Why the role matters
This is the closest PIPL concept to processor-style outsourcing, but contracts should use PRC statutory roles rather than mechanically importing GDPR labels.
CONTEXT
Where you see the term
ContextWhat it means there
Cloud / SaaSVendor processes customer or employee data for the client.
Payroll vendorProcesses employee information on instructions.
Vendor exitData should be returned or deleted as legally required.
TRANSLATION NOTE
文/A
Translation note
委托处理 is “entrusted processing” or “processing on commission”. It is functionally similar to controller–processor outsourcing but not textually identical to GDPR terminology.
AUTHORITY
Primary legal basis
ILLUSTRATIVE EXAMPLE
Example
A China company uses a payroll platform. The contract should specify processing instructions and security duties instead of merely calling the vendor an “independent controller”.
SOURCES AND REVIEW
Primary authorities.
18 Sep 2026
OFFICIAL SOURCESUPPORTSCHECKED
PRC Personal Information Protection Law
PRC Personal Information Protection Law
MAINTAINED BYChina Legal Portal Editorial
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