PIPLData PrivacyChinaAll Industries

Personal Information Protection Law of China

China comprehensive data protection law with strict requirements for processing personal information of individuals in China, including data localization requirements.

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The Mapping

What your auditor cites,
and what produces the evidence

The regulator's text is quoted below in italic, exactly as written. What follows each one is what the platform records, detects, or proves — not a claim about your compliance status, which no tool can confer.

PIPLArticle 51Patching, hardening, and exposureA record of access

Security Measures

Personal information handlers MUST adopt necessary measures to ensure processing activities comply with laws and prevent unauthorized access.

Continuous scanning checks each engine and version against known CVEs, missing patches, end-of-life versions, and hardening benchmarks, and extends to the network: exposed listeners, unexpected reachability, weak TLS, and drift from the documented baseline. Findings rank by exploitability and by the classification of the data at risk, so the same CVE sits differently in the queue on classified data than on a development copy — and the scan history is the evidence that the control operated continuously rather than quarterly.

PIPLArticle 55Assessment backed by evidence

Impact Assessment

REQUIRES personal information protection impact assessment before processing sensitive personal information.

An assessment is only defensible if the findings in it are observed rather than asserted. Discovery supplies what regulated data exists and where, scanning supplies the configuration and exposure posture, and the audit trail supplies who has actually been reaching it — so the assessment describes the estate as measured. Our advisory engagements then map each finding to the specific mandate it touches and sequence the remediation.

PIPLArticle 57Detecting it in time to notifyRouting and evidencing the response

Incident Response

In case of data breach, handlers MUST immediately take remedial measures and notify authorities and individuals.

Notification clocks start when you become aware, so detection latency is the whole exposure. Behavioural baselines score each deviation as it happens and flag it in under a second, rather than surfacing it in a weekly review. Severity is decided at the collector and routed immediately, so the window between the access and someone knowing about it is measured in seconds — and the audit trail behind it already holds what was reached, by whom, and when.

PIPLArticle 40Policy, procedure, and documentation

Cross-Border Transfer

Cross-border data transfers REQUIRE security assessment, certification, or standard contracts.

This mandate asks for documented policy and procedure rather than telemetry, so the platform is the evidence layer beneath it rather than the control itself. Our advisory engagements organise that documentation — a gap register mapping each requirement to its current state and a named owner, a sequenced remediation roadmap, and quarterly auditor-ready packs — and we answer the database-controls questions during the audit window. Drafting and owning the policy stays with you; assembling the evidence that it operates does not have to.

What PIPL covers

Art. 4; sensitive personal information at Art. 28

Information recorded electronically or otherwise relating to identified or identifiable natural persons within China.

In scope

  • Any recorded information relating to an identifiable natural person

Sensitive personal information (Art. 28)

The instrument's own term, kept as it writes it — these labels differ between frameworks on purpose.

  • Biometric characteristics
  • Religious beliefs
  • Specially designated status
  • Medical health
  • Financial accounts
  • Individual location tracking
  • Any personal information of a minor under 14

What falls outside

Anonymised information, which Art. 4 places outside the definition.

The under-14 rule is a class boundary rather than a factor: a minor’s ordinary personal information is sensitive personal information by definition, which is stricter than the equivalent EU treatment.

PIPL, Art. 28 · as at 2026-08

How PIPL is enforced

Every figure below is the ceiling the instrument publishes about itself, not a prediction of what anything would cost. Enforced by The Cyberspace Administration of China and provincial-level authorities.

Published maximumChargedAs at
CNY 50 millionfor serious violations2026-08
5% of the previous year turnoverthe percentage limb for serious violations2026-08
CNY 1 millionfor an ordinary breach, alongside an order to rectify2026-08

Article 66 sets a two-step scheme: an order to rectify and a fine of up to CNY 1 million for ordinary breaches, escalating to the CNY 50 million or 5% ceiling where the circumstances are serious. The same article reaches the people who ran the processing, not only the company.

Separate criminal liability for infringing personal information exists under PRC Criminal Law and is prosecuted independently of Art. 66; it is not claimed here.

Who is personally on the hook

Who can be charged
The directly liable person in charge, and other directly liable staff
For what
directing or permitting personal information handling that breaches the Law
Maximum
A personal fine of CNY 100,000 to CNY 1 million, and a bar on serving as a director, supervisor, senior manager, or person in charge of a relevant company for a set period
Brought by
The Cyberspace Administration of China and provincial authorities
Provision
PIPL Art. 66
Personal fineDisqualificationNot indemnifiable

Uncapped exposure that sits outside this instrument

These come from company law rather than from PIPL, and they are not penalties — they are liability for a loss, which is why nothing caps them at a published maximum.

Duty of oversight

Delaware, and followed in most US corporate jurisdictions. It is a rule of company law, not of any privacy or security statute.

Triggered by. A sustained or systematic failure by the board to establish a reporting system for a mission-critical risk — or, having one, consciously disregarding what it reported. The second limb is what a documented, unremediated finding goes to.

Who. Directors, in their personal capacity, in a derivative action brought on behalf of the company.

This is liability for the loss the company suffered, not a statutory penalty, so nothing caps it at a published maximum. A bad-faith finding also takes the conduct outside the exculpation and indemnification the charter would otherwise provide.

In re Caremark Int’l Deriv. Litig. (Del. Ch. 1996); Marchand v. Barnhill (Del. 2019); In re Boeing Co. Deriv. Litig. (Del. Ch. 2021).

Enforcement data reviewed August 2026. Several figures are indexed annually and move.

Ships With It

Built for PIPL,
not configured for it afterwards

Policy Template

China Data Processing Monitor

Track all processing of Chinese resident personal information

Report

PIPL Impact Assessment

Document processing activities for impact assessment requirements

Classification

Chinese PII Patterns

Detect Chinese ID numbers, phone formats, and sensitive categories

Alert

Cross-Border Transfer Detection

Alert when data matching Chinese residents is accessed from outside China

Other Data Privacy frameworks

Walk into the PIPL audit knowing the answer

228 cited requirements across 57 frameworks are mapped to the controls that evidence them. A fixed-fee gap assessment tells you which of them you can already prove today.

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