This year’s shopping season has already begun, and it’s not Black Friday that sets the tone this time but 双十一(Singles Day), China’s 11 November shopping festival, which has become the world’s largest online retail event. Millions of consumers will shop across multiple platforms, leading to unprecedented volumes of transactions and data flows within hours. For data protection and privacy teams, it marks not a celebration but the start of the busiest and riskiest period of the year. 

Key risks during the Singles Day season 

The success of Singles Day depends on speed and visibility, yet these same qualities often create weak points for privacy and security. When new data flows appear overnight and external vendors multiply, even small oversights can turn into regulatory risks. 

  • Outdated cookie consent and tracking tools: many retailers refresh promotional pages without reviewing cookie settings, which leads to unauthorised tracking or consent mismatches under GDPR and PIPL 

  • Payment security vulnerabilities: traffic spikes can overload payment gateways and expose weak controls. Encryption, multifactor authentication and fraud detection must be validated before peak activity 

  • Phishing and fake promotions: fraudulent sites and discount emails mimic legitimate brands and capture credentials or payment details 

  • Third-party and vendor risks: marketing agencies, delivery partners and cloud providers often receive broad access to customer information without timely permission reviews 

Beyond these headline risks, DPOs should remain alert to other vulnerabilities. These may include excessive data collection in promotional forms or the use of untested AI-driven tools that process personal data without proper assessment. The risk landscape is dynamic, and the examples above are not exhaustive. Continuous monitoring and coordination with security teams are essential. 

What DPOs and privacy teams should prioritise 

The first priority is to ensure clear and valid consent. DPOs and privacy teams should confirm that cookie banners and consent management tools are fully functional across all campaign pages. Consent must be obtained before tracking begins, and withdrawal should be as simple as acceptance. Testing banners in both English and Chinese versions helps identify configuration issues that could create compliance gaps. 

The next is payment and transaction security. DPOs and privacy teams should work with IT and finance teams to review payment gateway configurations, encryption standards and fraud-monitoring systems. Routine checks of TLS certificates and authentication settings help prevent disruptions during peak hours. A quick simulation of payment failure or breach notification flow can confirm whether internal processes are responsive and well-documented. 

Incident response planning should not be overlooked. A short internal drill focused on phishing or credential compromise helps teams clarify their roles in case of a real breach. DPOs and privacy teams should also ensure that after-hours contact lists are available and that escalation paths are known to all key teams. Keeping a short written record of these exercises strengthens accountability and prepares the organisation for regulator enquiries. 

Third-party oversight is equally important. DPOs and privacy teams should re-evaluate their marketing and logistics vendors, confirming that Data Processing Agreements are current and that contact points for incident notification are clear. Temporary campaign partners should only access the data necessary for their function, and permissions should be revoked once the campaign ends. For retailers selling through large marketplaces such as Taobao or JD.com, it is also important to understand how customer and order data are shared between their store accounts and the platform’s built-in analytics or advertising tools. DPOs and privacy teams should ensure that these integrations respect consent preferences and that any cross-border storage by the platform is transparently reflected in privacy notices. 

Outlook and next steps 

When the shopping rush ends, DPOs should lead a brief post-event review to capture lessons learned and remove temporary data access rights. Integrating these checks into regular compliance routines can strengthen long-term governance and improve readiness for future campaigns. With clear preparation and good coordination, DPOs can ensure that festive sales bring growth rather than data incidents.  

HewardMills supports organisations in maintaining resilient and compliant privacy programmes throughout every season of business activity. Our team includes native Chinese speakers and local partners, enabling us to guide clients through Chinese-language systems and ensure alignment with both local and international privacy standards. If you need DPO support this shopping season, don’t hesitate to get in touch.