Personal Information Protection and Privacy Policy Compliance of Health Code Apps in China: Scale Development and Content Analysis
Bibliographic record
Abstract
Background: Digital technologies, especially contact tracing apps, have been crucial in monitoring and tracing the transmission of COVID-19 worldwide. China developed health code apps as an emergency response to the pandemic with plans to use them for broader public health services. However, potential problems within privacy policies may compromise personal information (PI) protection. Objective: We aimed to evaluate the compliance of the privacy policies of 30 health code apps in the mainland of China with the Personal Information Protection Law (PIPL) and related specifications. Methods: We reviewed and assessed the privacy policies of 30 health code apps between August 26 and September 6, 2023. We used a 3-level indicator scale based on the information life cycle as provided in the PIPL and related specifications. The scale comprised 7 level-1 indicators, 26 level-2 indicators, and 71 level-3 indicators. Results: The mean compliance score of the 30 health code apps was 59.9% (SD 22.6%). A total of 13 (43.3%) apps scored below this average, and 6 apps scored below 40%. Level-1 indicator scores included the following: general attributes (mean 85.6%, SD 23.3%); PI collection and use (mean 66.2%, SD 22.7%); PI storage and protection (mean 63.3%, SD 30.8%); PI sharing, transfer, disclosure, and transmission (mean 57.2%, SD 27.3%); PI deletion (mean 52.2%, SD 29.4%); individual rights (mean 59.3%, SD 25.7%); and PI processor duties (mean 43.7%, SD 23.8%). Sensitive PI protection compliance (mean 51.4%, SD 26.0%) lagged behind general PI protection (mean 83.3%, SD 24.3%), with only 1 app requiring separate consent for sensitive PI processing. Additionally, 46.7% (n=14) of the apps needed separate consent for subcontracting activities, while fewer disclosed PI recipient information (n=13, 43.3%), safety precautions (n=11, 36.7%), and rules of PI transfer during specific events (n=10, 33.3%). Most privacy policies specified the PI retention period (n=23, 76.7%) and postperiod deletion or anonymization (n=22, 73.3%), but only 6.7% (n=2) were committed to prompt third-party PI deletion. Most apps delineated various individual rights: the right to inquire (n=25, 83.3%), correct (n=24, 80%), and delete PI (n=24, 80%); cancel their account (n=21, 70%); withdraw consent (n=20, 60%); and request privacy policy explanations (n=24, 80%). Only a fraction addressed the rights to obtain copies (n=4, 13.3%) or refuse advertisement of automated decision-making (n=1, 3.3%). The mean compliance rate of PI processor duties was only 43.7% (SD 23.8%), with significant deficiencies in impact assessments (mean 5.0%, SD 19.8%), PI protection officer appointment (mean 6.7%, SD 24.9%), regular compliance audits (mean 6.7%, SD 24.9%), and complaint management (mean 37.8%, SD 39.2%). Conclusions: Our analysis revealed both strengths and significant shortcomings in the compliance of privacy policies of health code apps with the PIPL and related specifications considering the information life cycle. As China contemplates the future extended use of health code apps, it should articulate the legitimacy of the apps' normalization and ensure that users provide informed consent. Meanwhile, China should raise the compliance level of relevant privacy policies and fortify its enforcement mechanisms.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.002 | 0.000 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".