Abstract
The thesis focuses on the personal information protection legislation in China, which hasn't been formally legislated yet.It approaches the legislation of Chinese personal information protection by comparison with the European Data Protection Directive, US legislative model and APEC Privacy Framework. Through analysis of common grounds and differences of different legislative model,it depicts the proper model of the Chinese Personal Information Protection law. It also points out the principal drawbacks and challenges to the present draft of Chinese personal information protection law and provides legal advice to the resolution of the problems.