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 China’s 
                      Internet regulator, the Ministry of Information and Industry 
                      Technology, or MIIT, is close to releasing the final version 
                      of China’s first national standards for personal information 
                      protection. The release of “Information Security Technology 
                      - Guidelines for Personal Information Protection” 
                      (the “Guidelines”) represents China’s 
                      first foray into the field of data privacy regulation. Among 
                      the proposed requirements: A. 
                      Restrictions that would prevent the transfer of personal 
                      information overseas; B. 
                      A specific requirement that express consent be obtained 
                      for all third-party disclosures of personal information; 
                        C. 
                      Clarification on the definition of personal information 
                      to include any information that is able to be collected 
                      and processed, relates to individuals and by itself or in 
                      combination with other information could disclose the identity 
                      of the individual; or, D. 
                      All of the above. 
 
 
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