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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.

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

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2

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Sorena AI
Published Jul 5, 2026
Updated Jul 24, 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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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 device permission 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.
Citations
Question 2

Build and test the collection map

For every field, device permission, 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 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.
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Operationalize the requirement

Prepare the PIPL and data export evidence file

Sorena AI helps turn the answer to "What should an app collect as necessary personal information in China?" into assigned controls and retained evidence.

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Map official sources to evidence

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Primary sources

References and citations

PRC Personal Information Protection Law
cac.gov.cn
Referenced sections
  • PIPL supports the additional processing-basis, notice, minimization, retention, sensitive-information, child, security, rights, and PIPIA checks.
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