On 13 March 2020 the Tianjin Cyberspace Administration (Tianjin CAC) issued the Circular on the Special Governance of the Illegal Collection and Use of Personal Information by Apps for the Prevention and Control of the Coronavirus Outbreak, which requires the operators of apps (including mini-programs and website tools) that prevent and control COVID-19 to:

  • fulfil personal information obligations in accordance with the law;
  • provide relevant information on personal information protection online; and
  • carry out security-based self-assessments and rectification processes, where required.

The Tianjin CAC also organised relevant departments to assess and examine the collection and use of apps for the prevention and control of COVID-19. The Tianjin CAC may impose various penalties on app providers that are found to have illegally collected or used personal information, including:

  • ordering them to rectify the situation;
  • interviewing the app operator;
  • making the app public;
  • removing the app from the market; and
  • transferring the file to public security organs to pursue criminal liability if criminal activities are involved.

The Tianjin CAC also encouraged the public to submit complaints to its official WeChat account (Cyberspace Administration Tianjin) or official email address ('[email protected]') regarding the illegal collection and use of data by apps designed to prevent and control COVID-19.

Following the issuance of the circular, on 16 March 2020 the Tianjin CAC reported the first results of the initiative. Seven apps were found to have illegally collected and used personal information and to have failed to provide the relevant information online. The Tianjin CAC required the operators of the seven apps to immediately provide the relevant information online, complete a rectification process and submit a rectification report before 21 March 2020. Failure to comply with these measures will result in the file being sent to the relevant public authority.