China

Comprehensive

Personal Information Protection Law (PIPL)

Authority: Cyberspace Administration of China (CAC) | Enforcement: Active | Enacted: November 2021

Overview

China's PIPL, effective November 2021, alongside the Data Security Law and Cybersecurity Law, creates one of the world's most comprehensive (and strict) data governance frameworks. Notable for strong data localisation requirements, strict cross-border transfer rules, and significant penalties.

14-Topic Coverage

Data Protection Authority

Fully Addressed

CAC is the primary regulator. Sector regulators (PBOC, MIIT) also have jurisdiction.

Data Subject Rights

Fully Addressed

Rights to know, decide, restrict, refuse, access, copy, correct, delete, and portability.

Cross-Border Transfer

Fully Addressed

Strict rules: security assessment by CAC, standard contracts, or certification. Important data must undergo security assessment.

Breach Notification

Fully Addressed

Must notify authorities and individuals. Remedial measures required immediately.

DPO Requirements

Fully Addressed

Personal information protection officer required for organisations processing above volume thresholds.

Children's Data

Fully Addressed

Parental consent required for children under 14. Classified as sensitive personal information.

Penalties & Enforcement

Fully Addressed

Up to RMB 50 million or 5% of annual revenue. Responsible individuals can be fined and banned from executive positions.

Sector-Specific Rules

Fully Addressed

Cybersecurity Law, Data Security Law, financial data rules, automotive data rules, health data regulations.

AI & Automated Decisions

Fully Addressed

Right to refuse automated decisions. Regulations on algorithmic recommendations, deep synthesis (deepfakes), and generative AI.

Data Localisation

Fully Addressed

Critical Information Infrastructure Operators must store data locally. Important data subject to security assessment for export.

Significant Data Fiduciary

Fully Addressed

Concept of "important data" and CII operators triggers enhanced obligations.

Government Data

Fully Addressed

State organs have specific obligations under PIPL. National security exemptions apply.