Data Protection Compliacne Practice

As the world's leading provider of comprehensive telecommunication solutions, ZTE attaches great importance to data protection and considers the protection of personal data of users, customers, employees and all relevant parties as an important and default ethical requirement and behavior benchmark, which is integrated into product design and services Delivery and management of internal control activities. Under the unified guidance of the Compliance Management Committee, ZTE relied on the cooperation of the compliance professional department, the business unit compliance team, and the compliance audit department to carry out data protection legal research, rule conversion and practical exploration, and continuously improved the compliance work.

There are uncertainties in the interpretation of legal provisions, and at the same time, practice is much richer and more complex than legal requirements. In 2019, the compliance professional department and the business compliance team worked in collaboration, and planned, organized, solicited, and publicized good data protection practices to form a group of joint results, which were edited into a book called "ZTE Data Protection Compliance Good Practices (2019)" , deepening consciousness and accumulating experience in the context of business activity, and collaboratively solving the challenges of risk assessment and governance practices. This is of great significance for the compliance construction of emerging and complex professional fields.

In 2019, ZTE's Data Protection and Compliance Department closely tracked the regulatory situation , conducted research on law enforcement strengths and the basis for law enforcement, refined the focus of law enforcement, collected the overview of legislation in 22 countries, details of regulatory agencies, and analyzed 87 typical law enforcement cases (penalty amount, basis, time, case facts, violation analysis, compliance implications), supplement the data protection restricted behaviors through law enforcement cases, and grasp the pulse of supervision, providing direct guidance for the company's compliance strategy setting and risk preference selection accordingly. Based on the research, ZTE released the Selected White Paper on GDPR Law Enforcement Cases ,GDPR Law Enforcement Case White Paper (2019.5-2020.5) two years in a row，demonstrating excellent compliance capabilities and winning peer recognition.

In 2020, ZTE's Data Protection Compliance Department summarized the construction achievements of the compliance system and compiled and released ZTE Privacy Protection White Paper (2020). ZTE have comprehensively introduced ZTE's exploration and efforts in privacy protection from five aspects: privacy protection compliance strategy, framework, co-construction, practice, and events recording, to explain ZTE's compliance concept of proactive construction.