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当前,对于用户个人数据保护合规问题,不论是企业内部法务还是外部律师正面临越来越多的困惑。一方面,国内法律规定十分原则,法律适用产生许多模糊地带;另一方面,云计算、大数据等新兴业务也让数据保护合规问题变得更为复杂。本文就实务中最为突出的三大问题提出分析建议。问题一:如何判断是否为个人数据?个人数据是个人数据保护法的核心概念。判断特定数据是否属于
At present, more and more confusion is faced by both internal corporate lawyers and external lawyers regarding the compliance of users’ personal data protection. On the one hand, the domestic laws and regulations are very principled and have many ambiguities arising from the application of the law. On the other hand, emerging businesses such as cloud computing and big data have also made data protection compliance more complicated. This article puts forward the analysis suggestion on the three major problems that are most prominent in practice. Question 1: How to judge whether it is personal data? Personal data is the core concept of personal data protection law. Determine if the specific data belongs to