Joint processing means shared purpose-and-means — a vendor on instructions is entrusted, not joint.
PIPL treats two or more handlers who jointly decide purpose and means as jointly responsible. They should agree their respective rights and duties; individuals may exercise rights against either. This is closer to GDPR joint controllers than to a processor. A payroll vendor following a WFOE’s instructions is entrusted processing (sibling page), not joint. A group HQ and a China entity that co-design a CRM purpose can be joint or even two handlers. Get the role memo right before you draft the contract. Overseas joint handlers still need a CBDT path if PI leaves the PRC.
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.
Who decided the purpose?
One party or both.
PurposeWho picked the means?
Shared architecture vs instruction-only.
MeansIs there an entrusted contract instead?
Vendor sibling.
VendorDoes PI leave China?
Add SCC/assessment/certification.
ExportWorking 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.
Can the individual sue either party?
PIPL lets people exercise rights against either joint handler. Contractual allocation does not erase that.
Is a group company always joint?
No. HQ can be a separate handler, a joint handler, or a recipient. Map the decisions.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.