Conducting compliance investigations in China: a new regulatory environment

Peter Humphrey and his wife were indicted by a Shanghai court on 8 August 2014 for illegally obtaining and selling private information of Chinese citizens. The private information included residential addresses, family member information, car ownership records and real-estate records. The couple operated ChinaWhys Co, a private investigation firm that offered investigatory services to corporations and law firms doing business in the People’s Republic of China (PRC).

At the time of their arrest, the couple were investigating Chinese citizens on behalf of GlaxoSmithKline (GSK), the UK pharmaceutical company. The arrest came days after Chinese authorities publicly levelled bribery allegations against GSK, which hired investigators to determine the identity of the person(s) that disclosed the bribery scandal to Chinese authorities and GSK executives. This arrest is indicative of a shift in China’s regulatory landscape toward tightened privacy compliance regulations and proactive enforcement of data privacy violations with respect to Chinese citizens.

The following article highlights certain lessons that can be learned from the Humphrey case and provides practical advice for navigating the risks associated with internal investigations in China…

Click on the link below to read the rest of the Dentons briefing.

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