Current-law scope and cautions
- PIPL treats personal information of children under 14 as sensitive personal information and requires guardian consent plus dedicated processing rules.
- The 2019 CAC Provisions on Cyber Protection of Children’s Personal Information add purpose limitation, minimization, security and guardian-facing requirements.
- Do not assume a generic click-through consent is sufficient for every sensitive-processing scenario; preserve evidence of the guardian-consent workflow.
Use: This is a screening/estimation tool, not a legal opinion. Confirm the latest primary authority, regulator practice, local rules and transaction documents before acting.
