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It’s well-known that China’s data protection laws define sensitive personal information very differently to other jurisdictions. Instead of a closed list of data types, sensitive personal information in China has...more
On July 18, 2025, the Cyberspace Administration of China (the “CAC”) issued the Notice on Launching the Reporting Mechanism for Personal Information Protection Officers (the “Notice ”). This development marks a significant...more
China’s primary data regulator, the Cyberspace Administration of China (CAC), released two sets of Q&As with respect to exporting data from China, one in April and one in May. The questions were selected from those raised...more
This monthly report outlines key developments in China’s data protection sector for June. TC260 Two Cybersecurity Practice Guidelines on Personal Information Protection Compliance Audits: On May 19, 2025, TC260 issued two...more
The Measures outline requirements and procedures for self-initiated and regulator-mandated compliance audits from May 1, 2025....more
On 14 February 2025, the Cyberspace Administration of China (“CAC”) issued the “Administrative Measures for Personal Information Protection Compliance Audits” (the "Measures"), which will take effect on 1 May 2025. The...more
This monthly report outlines key developments in China’s data protection sector for April....more
On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more
This monthly report outlines key developments in China’s data protection sector for March. The following events merit special attention...more
The PRC Personal Information Protection Law (PIPL) mandates regular data compliance audits. Following a consultation period beginning in August 3, 2023, the Cyberspace Administration of China (CAC) issued the Measures for...more
On February 14, 2025, the Cyberspace Administration of China ("CAC") finalized the "Personal Information Protection Compliance Audit Measures" ("Audit Measures"), which refines the draft version released on August 3, 2023...more
On January 3, 2025, the Cyberspace Administration of China (the “CAC”) released the Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers (the “Draft Measures”) for public comment....more
Chinese data regulators are intensifying their focus on the data protection compliance audit obligations under the Personal Information Protection Law (“PIPL“), with the release of the Administrative Measures for Personal...more
The Personal Information Protection Law (“PIPL“) requires a data controller to conduct compliance audits of its personal data processing activities on a regular basis (“Self-supervision Audits“). Apart from such...more
On March 22, 2024, the Cyberspace Administration of China (the "CAC") issued the highly anticipated final Regulations on Promoting and Regulating Cross-Border Data Flows (the "Regulations on Cross-Border Data Flows"),...more
The newly promulgated measures increase the threshold of data triggering security assessments and contract requirements while leaving room for Chinese authorities to heavily restrict cross-border data transfers. In...more
In Part 2 of this series, we discussed how the Personal Information Protection Law (“PIPL”), the centerpiece of China’s personal information (“PI”) protection law, needs to be read in conjunction with other relevant laws,...more
The Cyberspace Administration of China (“CAC”) on November 14, 2021 published the draft Regulations on the Administration of Network Data Security (“Draft Regulations”) for comment through December 13, 2021.1 The Draft...more
The Cyberspace Administration of China has issued draft guidance on applying for and conducting security assessments for cross-border data transfers for public comment. On October 29, 2021, the Cyberspace Administration of...more
China has recently joined the list of countries that have adopted the world’s strictest data-privacy laws. Given China’s desirability as both a market for and a source of data, companies worldwide have started making early...more
The PIPL imposes extensive obligations on organizations and individuals engaged in "handling" of personal information, which is defined to include "collection, storage, use, processing, transmission, provision, disclosure,...more