关键词: 个人信息保护, 基本路径, 差异与共性, 比较分析, 重思建构

Abstract: From the perspective of cultural comparison, different countries or regions have different ways of protecting citizens’ personal information. However, in the age of information, influenced by the sociality and sharing characteristics of information, the goals and tendencies of personal information protection mode show similarities. In China newly published “Personal Information Protection Law of the People’s Republic of China”(PIPL), the national security oriented thinking is still in an important position. In the process of review, it is faced with the discretion and choice of the protection or utilization of personal information. Referring to the beneficial experience of other countries and combining with China’s local conditions, when reviewing and interpreting the PIPL, China should take public interest as the standard to protect personal information rights and interests or promote utilization of information, recognize the nature of information, build the mechanism of data sharing and circulation, incorporate the principle of trust into the personal information protection law, and propose China’s scheme on personal information protection approach.

Key words: personal information protection, basic ways, differences and similarities, comparative analysis, rethinking and construction