Behavior structure and normative path of personal information"gatekeeper"obligation
It is necessary to re-examine existing norms in order to effectively address the new risks brought about by"gatekeepers".Although Article 58 of The Personal Information Protection Law stipulates the"gatekeeper"clause,it does not elaborate on the specific content of obligations.In interpretive theory,it is necessary to clarify the particularity of the behavior of"gatekeepers"and clarify the embeddedness and externalization of their behavior.Distinguish the two-level behavior structure of"gatekeepers"and construct a compliance system for data processing obligations and business management obligations.By combining the pre-regulation with the post-punishment,a dynamic regulatory path is formed.