Personal Health Data Anonymization in China: The Legal Framework and Its Refinements

China has adopted a dual approach to managing the anonymization of personal health data. In the context of the increasing collection of personal health information, china's current legal standards and practices of data anonymization are inadequate for data protection and utilization. In particular, the requirements of “unidentifiable” and “irreversible” for anonymized data are too high to achieve, and cannot properly address the challenges posed by technological progress. There are also inherent conflicts between the standards of “unidentifiable” and “irreversible” with the guidelines of “de-identification”. These issues affect the effective use of health data and the protection of individual privacy in China. Through a comparative analysis of the EU's “risk management” approach and the US's “de-identification” method in data anonymization, this paper explores the possibility of optimizing the “risk management” approach and the “de-identification” operation to reduce the regulatory uncertainty while enhancing data anonymization protection. The paper proposes suggestions for revising and improving the requirements for personal health data anonymization in China. To better adapt to technological changes and the diverse needs for information use, this paper argues for the establishment of a dynamic legal framework that protects privacy and promotes data utilization, as well as draws on international practices to provide more flexible and adaptable legal responses.