ISMS Copilot
China PIPL

China PIPL Copilot

Navigate China's Personal Information Protection Law and the CAC cross-border routes with confidence

What the China PIPL Copilot Can Do

Classify data correctly: personal information, sensitive personal information (biometrics, health, financial accounts, location, minors under 14), and anonymised data

Apply the lawful bases and the separate-consent triggers (sensitive personal information, cross-border provision); handle the automated decision-making duties (Article 24: transparency, explanations, refusal, no unreasonable price discrimination)

Assess cross-border transfers: the four Article 38 conditions and the 2024 Provisions' volume thresholds, exemptions and free-trade-zone negative lists

Draft the China-side documents: notices, consent flows, impact assessments, breach notifications, and the offshore-representative duty

Handle individual rights requests: access, copy, portability, correction, deletion (Articles 45-47)

Reason about penalty exposure with the Article 66 bands, including the 5%-of-turnover cap for serious cases

About China PIPL Copilot

The Personal Information Protection Law (个人信息保护法, PIPL) is China's general personal data protection statute. Adopted 20 August 2021, in force 1 November 2021, it has 74 articles in 8 chapters and applies to processing inside China and, extraterritorially, to offshore processing of the personal information of people in China that offers them products or services or analyses their behaviour. China PIPL Copilot helps organisations work through the lawful bases for processing (Article 13), separate-consent situations including sensitive personal information and cross-border provision (Articles 28-29, 39), the cross-border conditions of Article 38 (CAC security assessment, certification, the CAC standard contract, or other law/CAC conditions) with the operative thresholds of the 2024 Provisions, automated decision-making duties (Article 24), impact assessments (Articles 55-56), breach notification (Article 57), the rights regime (Articles 44-50), and the penalty exposure that reaches CNY 50,000,000 or 5% of prior-year turnover for serious violations (Article 66).

Cross-framework mappings

Working across China PIPL and another standard? ISMS Mappings is a free public directory of control maps (ISO 27001, SOC 2, NIST, GDPR, and more). A Better ISMS tool, separate from the chat assistant.

Browse free mappings

Frequently Asked Questions

What is China's PIPL?

The Personal Information Protection Law (个人信息保护法) is China's general data protection law, adopted 20 August 2021 and in force 1 November 2021. It is supervised by the Cyberspace Administration of China (CAC) and sector regulators, and it reaches services offered from outside China when they target people in China or analyse their behaviour (Article 3). Source: official text via CAC, https://www.cac.gov.cn/2021-08/20/c_1631050028355286.htm (checked 22 October 2026).

How does the China PIPL Copilot help?

China PIPL Copilot helps you interpret the law's data categories, apply consent and separate-consent rules, run the cross-border analysis against Article 38 and the 2024 Provisions, draft notices, impact assessments and breach notifications, and answer rights requests. It is advisory documentation support in Chinese or English, not a law firm and not legal advice. The dedicated China framework knowledge modules ship with the next product release; Chinese-language answers about PIPL work today.

When can personal information leave China under PIPL?

Article 38 lists the conditions: a CAC-organised security assessment, personal information protection certification, the CAC standard contract with the overseas recipient, or other conditions set by law or CAC rules, with an international-treaty route alongside. The 2024 Provisions (CAC Order No. 16, in force 22 March 2024) set the operative volumes: security assessment for critical information infrastructure operators, for non-CIIO processors providing important data abroad, and for transfers covering 1,000,000 or more individuals' non-sensitive personal information or 10,000 or more individuals' sensitive personal information in a year; the standard contract or certification for 100,000 to under 1,000,000 non-sensitive or under 10,000 sensitive; and exemptions below 100,000 non-sensitive (non-CIIO only), for contract-necessity cases, cross-border HR management under lawful labor rules, and emergencies. Sources: PIPL via CAC and the 2024 Provisions, https://www.cac.gov.cn/2024-03/22/c_1712776611775634.htm (checked 22 October 2026).

What are the penalties for non-compliance?

Article 66: refusing to correct brings fines up to CNY 1,000,000 for the organisation; serious violations bring confiscation of illegal gains and a fine of up to CNY 50,000,000 or 5% of the prior year's turnover, possible business suspension, and revocation of licences or business registration, with personal fines up to CNY 1,000,000 and profession bans for the directly responsible persons.

How does PIPL relate to the Cybersecurity Law and the Data Security Law?

They form one stack. The Cybersecurity Law (revised consolidated text in force 1 January 2026) sets network-operator and Multi-Level Protection Scheme duties; the Data Security Law sets data-management duties including the important-data regime; PIPL is the personal-data layer. Most China programmes need all three, plus the cross-border routes for transfers. See /regions/china for the full picture.

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