QuestionChina

What is separate consent under PIPL? Direct answer

Separate consent is a distinct consent for a specified activity, given after the person receives the information required for that activity. PIPL requires it for several higher-risk uses, but does not prescribe a screen design or button.

Identify the exact statutory trigger, present the activity-specific notice, record the person's affirmative choice, and reassess the consent if the purpose, method, or information changes.

Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
Questions
2

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Primary sources
1

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

PIPL has applied since November 1, 2021. is a distinct consent for a specified processing activity. Where consent is required, PIPL calls for separate consent when a processor provides personal information to another personal information processor, publicly discloses personal information, uses public-place images or identity information for a purpose other than public security, processes sensitive personal information, or provides personal information outside China. The law does not define a particular user-interface pattern.

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Question 2

How to implement and document the choice

PIPL does not mandate a checkbox, modal, signature, or other specific interface. Use a design that makes the specified activity clear and captures an affirmative choice separate from unrelated permissions. Do not describe a bundled acceptance of terms as merely because the notice mentions the activity.

Keep enough evidence to reconstruct what the person saw and did. This is an operational record, not an official form prescribed by PIPL.

  • Decision record: statutory trigger, Article 13 basis, purpose, processing method, information categories, recipients, necessity analysis, and responsible owner.
  • Notice evidence: the exact notice version, language, required recipient or overseas-transfer details, and when it appeared in the user flow.
  • Choice evidence: account or device identifier where appropriate, affirmative action, timestamp, notice version, scope of consent, and later withdrawal or renewal.
  • Related controls: the Article 55 PIPIA where triggered, retention rule, security measures, rights-request path, and a change trigger for a new purpose, method, category, or recipient.
Citations
PRC Personal Information Protection Law

Articles 14 and 15 support the consent and withdrawal record; Articles 17, 23, 30, and 39 identify notice content; Article 55 identifies processing that requires a prior PIPIA.

Primary sources

References and citations

cac.gov.cn
Referenced sections
  • Articles 14 and 15 support the consent and withdrawal record; Articles 17, 23, 30, and 39 identify notice content; Article 55 identifies processing that requires a prior PIPIA.
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