More foreign travelers seeking help at Shenzhen North Station—what legal compliance points lie behind the multilingual volunteer services?
As the 2026 APEC conference approaches, a multilingual team of "blue vest" volunteers has recently appeared at Shenzhen North Railway Station, dedicated to assisting foreign travelers with inquiries, ticketing, translation, and other services. According to statistics, within just one and a half weeks of its launch, the center served 111 people, including 36 foreign travelers. Behind these figures lies Shenzhen's efforts to enhance its international service standards, but they also raise an easily overlooked question: when public officials transform into "all-around guides" to assist foreign travelers, what legal boundaries are involved? What legal risks are concealed in the information collection, language communication, and itinerary suggestions during volunteer services? From a lawyer's perspective and based on current legal provisions, this article outlines the compliance points and response strategies for readers.
I. "Information Collection" in Volunteer Services and Personal Information Protection
When volunteers assist foreign passengers, they often need to obtain personal data such as their passport information, phone numbers, and travel itineraries. For example, helping passengers with ticket refunds or purchases may involve access to ticket details, and assisting with network connections may involve obtaining device information. These actions may seem routine, but they are directly governed by the Personal Information Protection Law of the People's Republic of China. Article 6 of this law stipulates that the processing of personal information should have clear and reasonable purposes, be directly related to those purposes, and be carried out in a manner that minimizes impact on individuals' rights and interests.
Volunteers, acting as "entrusted processors," are not "personal information processors" in the legal sense, and their actions remain bound by the delegation from state organs. Under Article 18 of the Personal Information Protection Law, processing sensitive personal information (such as travel itineraries or ID numbers) requires obtaining separate consent from the individual. In practice, volunteers should clearly inform passengers of the purpose of information collection before gathering it and avoid excessive collection. For instance, when assisting with ticket purchases, only necessary ticketing details should be recorded, and volunteers should not ask unrelated questions such as passengers' residential addresses or occupations.
Additionally, volunteer service organizations should sign confidentiality agreements with volunteers to clearly define the legal responsibilities for unauthorized disclosure of information. According to Article 1038 of the Civil Code, information processors must not disclose or tamper with the personal information they collect or store; without the consent of the natural person, they must not illegally provide their personal information to others. In the event of a breach, volunteers may face civil compensation and even administrative liability.
II. Legal Boundaries of "Language Services" in Multilingual Communication
Volunteers providing translation and guidance services to foreign travelers constitute a form of quasi-public service. Although there is currently no specific law targeting language services in volunteer work, the "Law of the People's Republic of China on the Standard Spoken and Written Chinese Language" stipulates that the public service sector shall use Putonghua as the basic service language. In foreign-related scenarios, using foreign languages is not illegal, but attention must be paid to the accuracy of the communication content.
If volunteers cause passengers to board the wrong train or purchase incorrect tickets due to translation errors, disputes may arise. For instance, as mentioned in the news, a Japanese traveler once bought the wrong ticket because of confusion between "Shenzhen Station" and "Shenzhen North Station," and it was through precise communication that the volunteer prevented a loss. Conversely, if a volunteer misunderstands key information such as station names or train numbers, it could constitute "misleading." According to Article 1165 of the Civil Code, a person who causes damage to another's civil rights and interests through fault shall bear tort liability.
Therefore, volunteers should possess basic legal knowledge and must accurately convey information concerning significant passenger rights, such as refund policies, visa requirements, and customs regulations. When necessary, they may advise passengers to verify details with official counters. At the same time, volunteers should avoid offering legal or policy advice beyond their capacity—for example, they must not casually assure passengers that they "can enter visa-free" or "will receive compensation"—so as not to create apparent authority, which could expose the service organization to legal liability.
III. Legal Assistance and Rights Protection Pathways for Foreign Travelers
When foreign travelers encounter disputes in Shenzhen, such as taxi refusals, hotel booking disputes, or consumer fraud, volunteers—though not legal professionals—play a crucial guiding role. Under the Exit and Entry Administration Law of the People's Republic of China and the Civil Procedure Law, foreign nationals in China enjoy the same litigation rights as Chinese citizens, but should pay attention to language and evidence-related issues.
When volunteers encounter such issues, they should guide travelers to call the 12345 government service hotline or visit Shenzhen's foreign-related legal service windows. Currently, Shenzhen has established multiple foreign-related legal aid centers that provide multilingual legal consultation. For example, if a traveler falls victim to consumer fraud, they may file a complaint with the market regulatory authorities in accordance with the Consumer Rights Protection Law; if a contract dispute is involved, written evidence should be preserved, and a lawyer should be hired if necessary. Volunteers should not make legal decisions on behalf of travelers but should provide informational support, avoiding liability arising from improper intervention.
Additionally, volunteers should also be familiar with legal procedures in emergency situations. If a passenger loses their passport, volunteers should assist them in contacting their country's embassy or consulate and reporting the matter to the police. In the event of personal injury, volunteers should immediately call 120 and preserve the scene to facilitate subsequent legal claims. These measures not only help passengers but also reduce the legal risks faced by volunteers themselves.
IV. Compliance of Public Officials Participating in Volunteer Services
This volunteer team is composed of public officials such as subdistrict cadres and community grid workers, and the special nature of their identity dictates that their conduct must be more rigorous. According to Article 59 of the Civil Servant Law of the People's Republic of China, civil servants shall not engage in or participate in for-profit activities. Although volunteer service is not for profit, accepting property from passengers during the service may violate disciplinary rules on integrity.
Meanwhile, public officials represent the government's image during volunteer services, and their words and actions may be deemed "official conduct." According to the State Compensation Law, if harm is caused to citizens through official conduct, the state is required to bear compensatory liability. Therefore, public official volunteers should strictly distinguish between volunteer services and administrative law enforcement, refrain from overstepping their authority in handling travelers' visa or customs matters, and instead guide them to official channels.
From an institutional perspective, Minzhi Subdistrict's establishment of a foreign language talent pool and encouragement of public officials to participate in services is commendable, but it requires a supporting training mechanism. Volunteers should receive basic legal training to understand common knowledge of foreign-related laws and risk prevention, avoiding "good intentions leading to bad outcomes." For example, when assisting travelers in connecting to public Wi-Fi, they should remind them to be cautious about cybersecurity to prevent theft of personal information; otherwise, they may bear corresponding liability for failing to fulfill the duty of safety notification.
V. Legal Advice for Passengers and Volunteers
For foreign travelers, when using volunteer services, they should proactively protect their personal information and avoid disclosing sensitive content such as passport photos and bank card numbers. If it is necessary to entrust a volunteer to operate a phone or make payments on their behalf, they must supervise on-site and keep transaction receipts. In the event of a dispute, legal channels can be pursued, as Shenzhen's foreign-related lawyer teams can provide bilingual services in both Chinese and English.
For volunteers, it is recommended to keep in mind the "three don'ts" principle: don't promise legal outcomes, don't make decisions on behalf of authorities, and don't collect irrelevant information. If complex legal issues arise during service, volunteers should guide travelers to consult professional lawyers or call the Shenzhen Legal Service Hotline at 12348. Guangdong Zhiming Law Firm has long focused on foreign-related legal affairs and can provide legal compliance guidance to foreign nationals and volunteer organizations, helping Shenzhen build a law-based and international business environment.
The "all-around guide" at Shenzhen North Station reflects the warmth of the city, and a clear legal boundary can make this warmth more enduring and secure.
