智通财经记者 | 张倩楠 2026年1月22日，最高人民检察院发布了一批个人信息保护检察公益诉讼典型案例。本次发布的典型案 例共6件，其中一起案例揭示了在招聘网站上发布虚假招聘广告骗取求职者个人信息的新型网络黑灰产 业。 广东省广州市天河区是广州市国际金融商业中心，吸引大量企业和人才汇聚。一些不法分子通过虚假注 册企业或者冒用他人公司名义的方式，在某招聘网站上发布虚假招聘广告，获取求职者上传简历内的姓 名、手机号码、籍贯、毕业学校及专业、入学及毕业时间、工作经历等个人信息，并非法出售牟利，给 求职者的人身安全、财产权益带来重大风险隐患，损害了社会公共利益。 智通财经编辑 | 刘海川 天河区院审查认为，根据《中华人民共和国个人信息保护法》《人力资源服务机构管理规定》《网络招 聘服务管理规定》等相关规定，结合相关职能部门权责清单和"三定方案"，天河区人力资源和社会保障 局（以下简称区人社局）、天河区市场监督管理局（以下简称区市监局）未充分履行对重点领域、重点 行业个人信息保护职责，对网络招聘平台长期监管不到位，致使社会公共利益持续受到侵害。 2023年12月14日，天河区院向区人社局、区市监局分别制发检察建议，督 ...

Core Viewpoint - The article highlights the emergence of a new type of cybercrime involving fraudulent job advertisements that deceive job seekers into providing personal information, prompting legal actions to enhance the protection of personal data in the online recruitment industry [1][2]. Group 1: Legal Actions and Investigations - The Tianhe District People's Procuratorate initiated an administrative public interest litigation investigation after discovering fraudulent activities during criminal case handling, revealing issues such as inadequate account verification on recruitment platforms and insufficient monitoring of abnormal recruitment behaviors [2]. - A total of over 37,000 personal information records were illegally obtained by criminals using "shell companies" to post fake job ads on recruitment platforms [2]. - The procuratorate developed a big data legal supervision model to analyze recruitment information and business registration data, identifying 61 leads related to fraudulent recruitment, which were forwarded to administrative agencies for further investigation [2]. Group 2: Regulatory Recommendations and Actions - The procuratorate issued recommendations to the Human Resources and Social Security Bureau and the Market Supervision Administration, urging them to enhance oversight of recruitment platforms and address issues related to "shell companies" and false job advertisements [3]. - Following the recommendations, the Human Resources Bureau conducted a special operation involving 450 personnel, resulting in actions against 6 fraudulent recruitment companies and 17 risky accounts, including account bans and warnings [3]. - The Market Supervision Administration expanded its investigation, placing 61 abnormal companies into an operating anomaly list and monitoring over 110,000 high-risk enterprises, leading to the investigation of 1,578 cases of false identity material registration and the imposition of fines totaling 1.5731 million yuan [3][4]. Group 3: Industry Impact and Future Directions - The article emphasizes that online fraudulent recruitment not only harms job seekers' rights but also disrupts the employment market order, necessitating a focus on regulatory gaps and key areas within the recruitment industry [4]. - The procuratorate aims to foster a multi-faceted governance model involving "procuratorial supervision + administrative enforcement + platform self-discipline" to promote the healthy development of the online recruitment industry [4].

Core Viewpoint The Supreme People's Procuratorate has released six typical cases of public interest litigation related to personal information protection, highlighting the importance of safeguarding citizens' personal data in various sectors, including smart parking, facial recognition, and online job recruitment. The initiative aims to enhance the enforcement of personal information protection laws and promote comprehensive governance in cyberspace. Group 1: Overview of Cases - The released cases cover issues such as smart parking, facial recognition in residential areas, online job scams, "box opening" incidents, and the misuse of personal information by scalpers and travel agencies [1][2] - The publication aims to implement the directives from the 20th Central Committee regarding the deepening of cybersecurity governance and the strengthening of personal information protection [1][2] Group 2: Specific Cases - Case 1: In Hebei, the procuratorate addressed issues with smart parking apps that collected excessive personal information, leading to a coordinated effort among multiple administrative bodies to rectify the situation [5][6][9] - Case 2: In Chongqing, the procuratorate focused on the misuse of facial recognition technology by property management companies, resulting in recommendations for regulatory compliance and industry-wide reforms [12][15][17] - Case 3: In Guangdong, the procuratorate tackled online job scams that exploited job seekers' personal information, utilizing big data to enhance oversight and promote systemic governance in the recruitment industry [20][22][24] - Case 4: In Zhejiang, the procuratorate initiated civil public interest litigation against individuals involved in "box opening" activities that violated personal privacy, emphasizing the need for judicial accountability [29][30][36] - Case 5: In Shanghai, the procuratorate addressed the illegal collection of personal information of deceased individuals and their relatives by healthcare workers, leading to regulatory recommendations to prevent such violations [37][38][41] - Case 6: In Jiangxi, the procuratorate focused on the misuse of personal information by scalpers and travel agencies in the tourism sector, advocating for stronger regulatory measures to protect personal data [46][47][50] Group 3: Legal and Regulatory Implications - The Supreme People's Procuratorate emphasizes the need for precise legal definitions and effective enforcement mechanisms in handling public interest litigation related to personal information protection [3][4] - The initiative aims to foster collaboration among various governmental departments to enhance the overall governance framework for personal information protection [3][4][19] - The cases serve as practical examples for improving the legal system surrounding personal information protection, highlighting the importance of public participation and technological support in enforcement efforts [3][4][19]

Group 1 - The core viewpoint of the article is that five government departments have jointly issued a notice to further regulate the publication of recruitment information on online platforms, aiming to protect job seekers' rights and create a more reliable job search environment [2][3]. - The new regulations address issues in the chaotic online recruitment market, such as the lack of rules and inadequate supervision, which have led to the proliferation of false information and unqualified recruitment services [2][3]. - The regulations set clear boundaries for behavior in the market by focusing on licensing management, account verification, and information standards, targeting the root causes of the existing problems [2][3]. Group 2 - The transition from "paper rules" to "practical order" remains a challenge, as platforms need to shift from prioritizing traffic to emphasizing management, which may increase operational costs [3]. - The virtual and cross-regional nature of online recruitment makes it difficult for a single regulatory body to cover all aspects of compliance, necessitating a more robust and ongoing regulatory mechanism [3][4]. - The regulation of the online recruitment market is a gradual process, and the implementation of these new rules is just the beginning of a longer journey towards order [4].

Core Viewpoint - The recent joint notice issued by multiple government departments aims to strengthen the governance of the online recruitment ecosystem and regulate the order of the online recruitment market [1] Group 1: Regulatory Requirements - The notice mandates that human resource service agencies must obtain a human resource service license to publish recruitment information or provide recruitment services on online platforms [1] - Online platforms are required to fulfill their primary responsibilities by enhancing account registration management and authenticating the real identity information of registered users [1] Group 2: Information Standards and Monitoring - The notice emphasizes the need for standardized formats for recruitment information, ensuring that all published information is truthful and legal, prohibiting illegal activities disguised as recruitment [1] - There is a call for enhanced monitoring of recruitment service accounts' online behavior, with a focus on promptly identifying and addressing illegal or non-compliant activities [1]

Core Viewpoint - The Ministry of Human Resources and Social Security, along with four other departments, has issued a notice to regulate the online recruitment information publishing, addressing issues such as unauthorized recruitment services and inadequate verification of employer qualifications and job postings [1] Group 1: Regulatory Requirements - The notice mandates enhanced regulatory oversight of online recruitment service licenses, requiring human resource service agencies to obtain a license before publishing job information or providing recruitment services [1] - Online platforms are required to fulfill their responsibilities by strengthening account registration management [1] Group 2: Information Standards and Monitoring - The notice specifies that online platforms must standardize the format of job postings, ensuring that the information is truthful and legal, and prohibits the use of job postings for illegal traffic diversion [1] - There is an emphasis on strengthening the regulation of recruitment service account activities and enhancing dynamic monitoring of job postings to promptly identify and address illegal activities [1]

Core Viewpoint - The Ministry of Human Resources and Social Security, along with four other departments, has issued a notice to regulate the online recruitment market, addressing issues such as unlicensed recruitment services and inadequate verification of employer qualifications and job information authenticity [1][3]. Group 1: Regulatory Requirements - Operating human resource service agencies must obtain a human resource service license to publish recruitment information on online platforms [2][3]. - Online platforms providing recruitment services must also acquire a human resource service license and clearly display qualification and certification information on their account homepage [2][4]. - The notice emphasizes the need for local authorities to monitor recruitment information published by online platforms and take administrative measures against illegal postings [4][5]. Group 2: Strengthening Account Management - Online platforms are required to enhance account registration management, ensuring real identity verification of registered users and categorizing account qualifications [5][6]. - The notice mandates that platforms must clearly label recruitment service accounts and display qualification information on their homepages [6][5]. - There is a recognition that some platforms prioritize traffic over management, leading to insufficient verification of recruitment information [5][6]. Group 3: Complaint and Violation Handling - The notice prohibits illegal practices such as misleading job postings and requires platforms to establish a rapid response mechanism for complaints and violations [7][8]. - Measures against violations include pop-up warnings, account suspension, and deletion of illegal postings [8]. - A system for maintaining a list of violators is to be established to prevent them from re-registering under different accounts [8].

Core Viewpoint - The recent notice issued by five departments, including the Ministry of Human Resources and Social Security, aims to regulate online recruitment practices, ensuring compliance and protecting job seekers' rights [1][2]. Group 1: Regulatory Measures - The notice mandates that human resource service agencies must obtain a human resource service license to publish recruitment information or provide recruitment services on online platforms [1]. - Local authorities are required to enhance the scrutiny of recruitment information published on online platforms, taking administrative measures against those that violate regulations [1][2]. Group 2: Platform Responsibilities - Online platforms are instructed to strengthen account registration management, requiring real identity verification for registered users and categorizing account qualifications [2]. - Recruitment information must be truthful and legal, including essential details such as employer information, number of positions, job requirements, work content, location, and basic salary [2]. Group 3: Prohibition of Misleading Practices - The notice strictly prohibits misleading job seekers into signing "recruitment transfer training" or "training loans" agreements and engaging in illegal activities such as pyramid schemes and online gambling [3]. - Online platforms must establish risk identification models and monitor recruitment information dynamically, taking prompt action against violations [3]. Group 4: Future Actions - The Ministry of Human Resources and Social Security plans to conduct targeted training to guide local authorities in refining regulatory measures and enhancing administrative guidance for online platforms [3]. - There will be a focus on improving inter-departmental collaboration to create a cohesive regulatory framework, integrating licensing, daily supervision, and law enforcement [3].

Core Viewpoint - The Ministry of Human Resources and Social Security, along with several other government bodies, has issued a notification to regulate the publication of recruitment information on online platforms, emphasizing the need for authenticity and legality in job postings [1][3]. Group 1: Regulatory Requirements - The notification mandates that human resource service agencies must obtain a human resources service license to publish recruitment information through various media [1]. - Online platforms providing recruitment services must also secure the necessary licenses and are required to conduct regular checks on job postings to ensure compliance [1][2]. - Platforms must implement strict account management practices, including real-name registration and regular verification of recruitment service accounts [2]. Group 2: Content Standards for Job Postings - Job postings must include essential details such as the employer's information, number of positions, job requirements, work content, location, and basic compensation, with a clear indication of validity periods [2]. - Discriminatory content based on ethnicity, gender, religion, or other factors is strictly prohibited in job advertisements [2]. - Any reposting of job information must clearly indicate the source of the information [2]. Group 3: Monitoring and Compliance - The notification emphasizes the prohibition of misleading practices such as false job postings and exaggerated claims to attract job seekers [3]. - Online platforms are required to establish risk identification models and enhance monitoring of recruitment service accounts to detect and address illegal activities promptly [3]. - The initiative aims to improve the governance of the online recruitment ecosystem and protect the rights of job seekers [3].

Investment Rating - The report maintains an "Outperform" rating for BOSS Zhipin (BZ.O) [3][20][6] Core Insights - The company reported a revenue growth of 13% year-on-year, with an adjusted profit margin of 46% in Q3 2025. Revenue reached 2.16 billion RMB, exceeding the upper limit of the company's guidance for Q2 2025 [1][8] - The demand for recruitment is showing healthy recovery, particularly in the white-collar and fresh graduate sectors, with a notable increase in enterprise hiring needs [2][16] - The company expects Q4 2025 total revenue to be between 2.05 billion RMB and 2.07 billion RMB, reflecting a year-on-year increase of 12.4% to 13.5% [2][16] Financial Performance - In Q3 2025, the gross profit margin was 85.8%, with sales expenses controlled well at 390 million RMB, a decrease of 25% year-on-year [1][8] - Adjusted net profit for Q3 2025 was 990 million RMB, representing a 34% increase year-on-year, with an adjusted net profit margin of 46% [1][8] - The company anticipates continued profit margin improvement in 2026 due to operational leverage [1][8] User and Market Dynamics - The platform's monthly active users (MAU) reached 63.8 million, a 10% increase year-on-year, while the number of paid enterprises grew by 13% year-on-year to 6.8 million [2][16] - The average revenue per user (ARRPU) for the past 12 months was 1,116 RMB, showing a slight decline of 1% year-on-year [2][16] - The company aims to add over 35 million new users in the upcoming year, driven by a recovery in recruitment demand [2][16] Profit Forecast - The report projects adjusted profits of 3.52 billion RMB, 4.41 billion RMB, and 5.49 billion RMB for the years 2025, 2026, and 2027, respectively [3][20][22]