WHAT 单独同意 MEANS
What 单独同意 means
The PIPL requires separate consent in several situations, including certain disclosures to other handlers, processing of sensitive personal information and cross-border transfers where consent is the applicable basis.
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Why the role matters
A blanket privacy-policy acceptance should not be assumed to satisfy separate-consent requirements. Product and HR flows may need a specific step tied to the relevant activity.
CONTEXT
Where you see the term
ContextWhat it means there
Sensitive informationSeparate consent is generally required.
Data sharingProviding personal information to another handler may trigger it.
Data exportCross-border provision may require separate consent and other mechanisms.
TRANSLATION NOTE
文/A
Translation note
单独同意 is best rendered “separate consent”. It means a discrete consent action, not merely stronger wording inside general terms.
AUTHORITY
Primary legal basis
AUTHORITY
Primary legal basis
ILLUSTRATIVE EXAMPLE
Example
A China app adds overseas cloud analytics. Updating the privacy policy alone may not be enough where the activity triggers separate-consent and data-export requirements.
SOURCES AND REVIEW
Primary authorities.
18 Sep 2026
OFFICIAL SOURCESUPPORTSCHECKED
PRC Personal Information Protection Law
PRC Personal Information Protection Law
CAC Provisions on Promoting and Regulating Cross-Border Data Flows (for current cross-border exemptions and mechanisms)
CAC Provisions on Promoting and Regulating Cross-Border Data Flows (for current cross-border exemptions and mechanisms)
MAINTAINED BYChina Legal Portal Editorial
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