PrivacyChina

China Privacy Law PIPL automated decision-making and personalized recommendations

PIPL checks for automated decisions, personalized recommendations, marketing, differential treatment, explanations, refusal rights, and impact assessments.

Article 24 applies when personal information is used to make decisions automatically. The required control depends on whether the system pushes information or marketing, changes transaction terms, or makes a major solely automated decision.

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Sorena AI

Published

Jul 5, 2026

Updated

Jul 24, 2026

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Cited legal and guidance references.

Publication metadata

Sorena AI

Published Jul 5, 2026

Updated Jul 24, 2026

Overview

If a system uses personal information to analyze or assess behavior, habits, interests, finances, health, credit, or another characteristic and then makes decisions automatically, treat it as under PIPL. Article 24 requires transparency and fair, impartial results, prohibits unreasonable differential treatment in transaction terms such as price, and gives additional choices for recommendations, marketing, and major solely automated decisions.

Section 1

Classify the feature before choosing the control

Inventory any feature that profiles, scores, ranks, recommends, targets, prices, approves, rejects, flags, or allocates using personal information. Examples can include a personalized product feed, a credit or fraud score, a price or discount rule, or an eligibility decision; the actual inputs and decision path determine coverage. Record the decision made, the input categories, the people affected, whether a person meaningfully participates, and the likely effect on rights or interests.

Article 24 contains three related rules. All must be transparent and produce fair and impartial results. Automated information pushes and commercial marketing must also offer either a non-personalized option or a convenient refusal method. A solely automated decision with a major effect on rights or interests gives the individual a right to an explanation and a right to refuse that solely automated decision.

Recommendation or marketing owner: provide the alternative or refusal where the output is an information push or commercial marketing. Test that the control is easy to find and changes subsequent processing.
Transaction owner: test whether similarly situated people receive different prices or other transaction terms, and document why any difference is reasonable and connected to a legitimate processing purpose.
High-impact decision owner: determine whether the decision materially affects eligibility, access, finances, work, health, safety, or another right or interest and whether it is made only through automation.
Human-review owner: a nominal approval is not enough evidence of meaningful human involvement. Record what information the reviewer sees, what authority the reviewer has, and whether the reviewer can change the outcome.

Sources for this answer

PRC Personal Information Protection Law

Articles 24 and 73 define automated decision-making and establish transparency, fairness, differential-treatment, non-personalized-option or refusal, explanation, and solely automated decision-refusal rules.

Section 2

Apply the ordinary PIPL duties too

Article 24 does not replace the rest of PIPL. Choose an Article 13 processing condition, give the Article 17 notice, collect only what is directly related and necessary, keep it for the shortest necessary period, support individual rights, and apply Article 51 security measures.

Complete a PIPIA before using personal information for . The assessment must address legality, legitimacy, necessity, effects on individual rights, security risks, and whether safeguards are lawful, effective, and proportionate. Keep the PIPIA and processing record for at least three years. PIPL has applied since 1 November 2021 and does not provide a general grandfathering exception for an automated feature that already existed on that date.

Data owner: record the source, accuracy, relevance, and sensitive-information status of each input. Sensitive personal information requires the separate Article 28-30 analysis.
Product owner: explain the purpose and practical effect in clear language. Do not describe the system so generally that a person cannot understand what choice or consequence is involved.
Rights owner: define intake, verification, response, explanation, refusal, complaint, and escalation steps. PIPL does not set one universal explanation format or response deadline for Article 24 requests.
Vendor owner: if a vendor processes personal information on instructions, include Article 21 terms and supervision; if the vendor independently decides purpose and method, assess the separate-recipient duties.
Monitoring owner: retest inputs, outputs, refusal behavior, non-personalized options, overrides, complaints, and differential outcomes after material model, rule, data, purpose, or population changes.

Sources for this answer

PRC Personal Information Protection Law

Articles 5-8, 13, 17, 21, 28-30, 44-56, and 59 establish processing conditions, notice, data quality, sensitive-information, rights, security, vendor, and PIPIA duties that also apply to automated decisions.

Section 3

Evidence for launch and ongoing review

A reviewer should be able to reconstruct the feature, legal analysis, implemented control, and observed outcome. Keep source facts and test results together so a later change does not leave the PIPIA or notice describing an old system.

Feature record: purpose, owner, affected population, inputs, data sources, output, decision path, human role, recipients, retention, and consequences.
Article 24 record: transparency copy, non-personalized option or refusal design, explanation procedure, solely automated decision-refusal procedure, and differential-treatment testing.
PIPIA record: risks to rights and interests, security risks, selected safeguards, residual risk, approver, date, and at least three years of retention.
Operating record: refusal and option tests, explanation requests, reviewer decisions, overrides, complaints, incidents, fairness monitoring, and material changes.
Boundary: this page cannot decide whether an effect is major or whether human involvement is meaningful without the product's facts, decision consequences, and actual reviewer authority.

Sources for this answer

PRC Personal Information Protection Law

Articles 24, 50, 55, and 56 support the Article 24 control record, convenient rights mechanism, pre-processing PIPIA, and three-year minimum retention.

Put the requirement into practice

Prepare the PIPL and data export evidence file

Assign owners, implement the Article 24 controls, and keep the feature, PIPIA, tests, requests, and changes connected.

Research workflow

Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

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Primary sources

References and citations

PRC Personal Information Protection Law

cac.gov.cn

Referenced sections

Articles 24, 50, 55, and 56 support the Article 24 control record, convenient rights mechanism, pre-processing PIPIA, and three-year minimum retention.

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