The Regulation of Personal Data Accuracy in China’s Public Social Credit System

34 Pages Posted: 3 Nov 2022

Date Written: October 10, 2022


The state-run Social Credit System (SCS), China’s mega-project to improve governance capabilities and legal compliance, depends on accurate data to achieve its purposes, but national-level regulation promoting it is slim. This study examines the overall regulatory framework dealing with the accuracy of personal information used in the public SCS, considering special sectoral and provincial regulations and national legislation such as the Personal Information Protection Law and the Regulation on Open Government Information. It frames the SCS as a data processing mechanism and discusses data input and use, as well as the overall legal framework it operates in. Subsequently it assesses the legal content of existing regulations with regard to ensuring data accuracy, focusing on accuracy obligations, notification requirements, prior review procedures, information accessibility, posterior objection procedures and the dissemination of changes throughout the system. The study finds that special legislation is inconsistent, and that national legislation is often too vague to deal with the complicated and diverse processes of the SCS. Further legislation will be needed to standardise procedures.

Keywords: Social Credit System, Data Accuracy, China, Data Protection, Public Social Credit Data

Suggested Citation

Klöber, Hannah, The Regulation of Personal Data Accuracy in China’s Public Social Credit System (October 10, 2022). Available at SSRN: or

Hannah Klöber (Contact Author)

University of Cologne ( email )

Albertus Magnus Platz
Cologne, NRW 50923

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