Recently, the General Office of the Human Resources and Social Security ("MOHRSS") and the General Office of the Ministry of Finance ("MOF") have jointly issued the Circular on Further Strengthening Protection of Private Data amid the Disclosure of Information on the Use of Employment Subsidies (the "Circular").
The Circular lays down arrangements from different perspectives, including "regulating the content made public", "focusing on self-inspections and rectification" and "tightening the use of information". Further, the Circular expressly states that all places shall work effectively on publishing information about the use of grants pursuant to requirements set forth in the Administrative Measures for Employment Subsidies (the "Measures"), and further regulate the content disclosed in accordance with applicable requirements on the protection of private data. For personal ID numbers that should be disclosed as stipulated in the Measures, they shall be wholly or partially concealed, when made accessible to the public. In principle, certain sensitive information in connection with the individual privacy of persons who receive the government grants, such as home address, contact, bank account number, date of birth, conditions of family poverty, and physical disability, shall not be published if the Measures do not require the disclosure of such information; even if it is truly necessary to do so, particular attention shall be paid to ensuring the security of private data and individual privacy.