China Data Compliance Check
Scan your website for China data compliance issues including PIPL, DSL, and CSL requirements. Verify ICP filing, privacy policy, cross-border data transfer statements, and user rights protection. Essential for companies operating in or targeting the China market.
What We Check
Beyond Website Scanning
Website scanning checks your public-facing compliance posture, but China's data protection laws require comprehensive internal governance measures.
Personal Information Impact Assessment (PIA)
PIPL Article 55 requires a Personal Information Protection Impact Assessment before processing sensitive personal information, automated decision-making, cross-border transfers, or delegated processing. PIAs must document processing necessity, risks to individual rights, and safeguard measures. The CAC can request PIA records at any time.
Cross-border Transfer Security Assessment
If your organization transfers personal information outside China, you may need to undergo a Security Assessment filed with the Cyberspace Administration of China (CAC). This applies to critical information infrastructure operators, organizations processing data of 1 million+ individuals, or those that have transferred data of 100,000+ individuals abroad since January of the prior year.
Data Localization Review
The Cybersecurity Law and PIPL require critical information infrastructure operators to store personal information collected within China domestically. Even non-CIIO organizations should assess whether their data storage architecture meets localization requirements, especially if using overseas cloud providers or centralized global databases.
Cybersecurity MLPS (等保 2.0)
The Multi-Level Protection Scheme (MLPS / 等保2.0) under the Cybersecurity Law requires network operators to classify their information systems into security levels (1–5) and implement corresponding technical and organizational controls. Level 2 and above require formal assessment by an accredited testing institution. Most commercial systems handling personal data fall into Level 2 or 3.
Data Security Classification
The Data Security Law (DSL) requires organizations to classify data based on its importance to national security, economic development, and public interest — categorized as general, important, or core data. Organizations must establish a data classification and grading system, implement corresponding security controls, and maintain records for regulatory inspection.
Internal Compliance Governance
PIPL Article 52 requires organizations processing personal information above certain thresholds to appoint a Personal Information Protection Officer and establish dedicated compliance departments. Article 51 mandates internal management systems, operational procedures, classification and grading of personal information, and regular compliance audits.
China's Data Protection Framework
China has established a comprehensive data protection framework through three key laws: the Personal Information Protection Law (PIPL), the Data Security Law (DSL), and the Cybersecurity Law (CSL). Together, these laws regulate how organizations collect, process, store, and transfer data within and outside China.
For companies operating in China or handling data of Chinese residents, compliance with these laws is mandatory. Violations can result in fines up to 50 million RMB or 5% of annual revenue, suspension of business operations, and personal liability for responsible individuals.
Frequently Asked Questions
What is PIPL and does it apply to my company?
The Personal Information Protection Law (PIPL) applies to any organization that processes personal information of individuals within China, regardless of whether the organization is based in China. If you have Chinese users, customers, or employees, PIPL likely applies.
Do I need an ICP filing?
Any website hosted in mainland China or providing services to Chinese users must have an ICP (Internet Content Provider) filing. This is a basic requirement under the Cybersecurity Law and is enforced by the Ministry of Industry and Information Technology (MIIT).
What are the cross-border data transfer requirements?
Under PIPL, transferring personal information outside China requires one of: passing a security assessment by the Cyberspace Administration of China (CAC), obtaining personal information protection certification, or signing standard contracts filed with the CAC.
What are the penalties for non-compliance?
Violations can result in fines up to 50 million RMB or 5% of annual revenue. Authorities can also order suspension of services, revoke business licenses, and hold individuals personally liable. The CAC has been actively enforcing these regulations since 2022.
What is MLPS (等保) and does it apply to my business?
The Multi-Level Protection Scheme (MLPS / 等保2.0) requires all network operators in China to classify their information systems into security levels and implement corresponding controls. If your system stores or processes personal information, handles payment data, or provides internet services to users in China, you likely need at least Level 2 certification, which requires formal assessment by an accredited testing institution.
Do I need to appoint a Personal Information Protection Officer?
Under PIPL Article 52, organizations that process personal information reaching thresholds set by the CAC must designate a person responsible for personal information protection and disclose their contact details publicly. While the exact thresholds are still being defined, any organization handling data of a significant number of Chinese users should proactively appoint a responsible person and establish an internal compliance framework.
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