QQuestions:
If a company contracts a service project to its Shanghai branch, is it related to the data processing practice in conformity with the Personal Data Protection Act? Must it notify the PDPB or apply for any approval?
AReply

A company may, based on its managerial needs, entrust personal data to other companies for processing, provided that it has established a contract of consignment binding on the consignee company, in such a way as to ensure the security and confidentiality of the data to be processed. Where such consignment incurs the transfer of personal data outside the MSAR, the transferring company must notify or apply to the PDPB for approval.

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