QuestionChina

What should an app collect as necessary personal information in China? Direct answer

Collect no more than the personal information necessary for the app's actual basic function, using the 2021 rules for the matching app category. A listed field may be permitted for that function; the list does not require the app to collect it.

Keep the basic function available when a user declines non-necessary information, and apply PIPL separately to every collection and use.

Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
Overview

China's necessary-personal-information rules took effect on May 1, 2021. Collect no more than the for the app's actual basic function. The rules define that term as consumer-side personal information without which the basic function cannot operate and give category-specific scopes for 39 common app types, including installed apps, preinstalled apps, and mini programs.

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2 of 2 questions
Question 1

Match the app to its basic function

Start with what the user is obtaining, not the app's marketing label. Match that basic function to the 2021 category and map each proposed field to the listed scope. If the app provides several distinct basic functions, document the category and necessary scope for each function rather than treating the broadest category as permission for the whole product.

The list sets the outer scope of information treated as necessary for each stated basic function. It does not require collection of every listed item when the app can deliver the function without it. It also does not make optional analytics, advertising, personalization, contacts, background permissions, or SDK events necessary merely because they support the business.

  • Map navigation: location, departure point, and destination are listed for the basic location-and-navigation function.
  • Online shopping and food delivery: the listed scope includes a registered mobile number, recipient name, address and contact number, and payment time, amount, and channel.
  • Instant messaging: the listed scope includes a registered mobile number plus the account and instant-messaging contact-account list.
  • Functions requiring no personal information: the rules list news browsing, online audio or video playback, short-video search and playback, browsers, input methods, photography or beautification, and several other categories as needing none for the stated basic function. Requiring account registration or a permission that collects non- before those basic functions would conflict with that category result unless another controlling rule applies.
  • Health, finance, transport, and other categories can include information that is sensitive under PIPL. The category table does not remove the separate sensitive-information duties.
Question 2

Build and test the collection map

For every field, device permission, software development kit (SDK), and event, record the product function, collection timing, recipient, purpose, and whether the item is necessary for the basic function. If it is outside the category scope or the function works without it, keep it out of the mandatory flow and do not block the basic function when the user refuses.

Then apply PIPL. Identify the processing basis, give the required notice, keep collection within the minimum necessary range, use the shortest necessary retention, and address sensitive personal information, children under 14, security, individual rights, and personal information protection impact assessment (PIPIA) triggers.

  • Category decision: basic-function description, selected 2021 category, any multi-function split, and product owner.
  • Field map: field or event, collection source, user action, basic function, necessity rationale, recipient or SDK, retention, and deletion.
  • Refusal test: evidence that declining each non-necessary field or permission leaves the relevant basic function available.
  • PIPL overlay: basis, notice, consent, sensitive-information classification, child treatment, security controls, rights path, and PIPIA where triggered.
  • Change trigger: reassess when a function, SDK, permission, field, use, recipient, or collection timing changes.
Primary sources

References and citations

cac.gov.cn3 citations
Referenced sections
  • Official source for the covered app forms, basic-function test, consumer-side scope, no-refusal rule, and 39 category-specific necessary-information scopes; effective 1 May 2021.
  • Articles 2-5 define covered apps, consumer-side necessary personal information, the no-refusal rule, and the category-specific scopes and examples.
  • The 2021 rules support the category decision, field map, and no-refusal test for information outside the necessary scope.
cac.gov.cn3 citations
Referenced sections
  • Binding source for the PIPL duties that still apply to collection permitted by the app-category rules.
  • Articles 5-19 and 28-31 supply the separate purpose, minimization, basis, notice, consent, retention, sensitive-information, and child rules.
  • PIPL supports the additional processing-basis, notice, minimization, retention, sensitive-information, child, security, rights, and PIPIA checks.
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