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What records should we keep for a PIPL impact assessment? Direct answer

Keep the report and the record of the assessed processing for at least three years. The file should connect the Article 55 trigger and actual processing facts to each Article 56 conclusion.

PIPL prescribes the assessment topics and retention period, but not a single official report format, score, or approval workflow.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
2 sections3 primary sources
Overview

PIPL has applied since November 1, 2021. Keep the report and the record of the assessed processing for at least three years. The file should identify why Article 55 applies, describe the real processing, assess every Article 56 topic, record the safeguards and decision, and show when a change requires a new assessment.

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2 of 2 questions
Question 1

Start with the trigger and actual processing

Complete a before processing sensitive personal information; using personal information for automated decision-making; entrusting processing; providing personal information to another processor; publicly disclosing it; providing it outside China; or carrying out another activity with a major effect on personal rights and interests.

Identify the system, business owner, processor role, people concerned, purpose, Article 13 basis, collection source, information categories, processing methods, recipients, locations, retention, deletion, rights handling, and security controls. The assessment should describe the intended operation, not only repeat a privacy notice or contract.

  • Scope record: assessment identifier, Article 55 trigger, systems and versions, owner, participating teams, decision date, and processing start date.
  • Data map: information fields and inferences, sensitive or child data, sources, people, volumes where relevant, recipients, entrusted parties, overseas locations, access paths, retention, and deletion.
  • Rule analysis: Article 13 basis, notices, consent or separate-consent requirement, necessity, minimization, individual rights, and any export-route dependency.
  • Change control: facts that require review, including a new purpose, method, information category, recipient, country, retention period, automated-decision use, or material risk.
Question 2

Record the Article 56 analysis and decision

Article 56 requires three conclusions: whether the purpose and method are lawful, legitimate, and necessary; the effect on personal rights and interests and the security risks; and whether the safeguards are lawful, effective, and proportionate to the risk. Show the facts, evidence, and reasoning behind each conclusion.

PIPL requires retention of the assessment report and processing record. It does not prescribe a universal template, risk matrix, named approver, mandatory report length, or retention rule for every supporting input. Use the organization's governance process, but label internal scoring, evidence attachments, sign-off fields, and any longer retention period as organizational controls rather than Article 56 requirements.

  • Legality, legitimacy, and necessity: source provisions, purpose, basis, less intrusive alternatives, minimum information, and shortest necessary retention.
  • Effects and risks: plausible misuse, leakage, unauthorized access, discrimination, loss of control, rights barriers, and severity and likelihood using the organization's defined method.
  • Safeguards: contractual, organizational, and technical measures; responsible owner; implementation status; test or review evidence; and why the measures match the risk.
  • Outcome: approved scope, conditions before launch, unresolved issues, risk acceptance under internal governance, reassessment triggers, and links to the processing record and implemented controls.
  • Retention: preserve the report and processing record for at least three years. Sorena recommends keeping material inputs, approvals, and control evidence with that file so a reviewer can reconstruct the decision; a longer period may follow from another applicable rule or the processing lifecycle.
Recommended next step

Assemble the PIPIA record

Keep the assessment trigger, processing facts, Article 56 analysis, safeguards, decision, and processing record together for at least three years.

Research workflow
Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

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Talk to Sorena
Review the China route

Check the China Privacy Law scope decision and unresolved launch questions with Sorena.

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Primary sources

References and citations

Measures for Security Assessment of Data Export
cac.gov.cn3 citations
Referenced sections
  • Binding source for the separate risk self-assessment and submission materials required for a CAC data export security assessment.
  • Articles 5-6 identify the separate data-export risk self-assessment and application materials when a CAC security assessment is required.
  • Use only when the export also triggers the CAC security-assessment route; its risk self-assessment is a separate, more detailed submission record.
Measures for the Standard Contract for Personal Information Export
cac.gov.cn3 citations
Referenced sections
  • Binding source for the additional PIPIA content, filing, and reassessment duties when using the personal-information export standard contract.
  • Article 5 adds export-specific PIPIA topics for the standard-contract route, including scale, sensitivity, overseas-recipient safeguards, rights channels, and the recipient country's legal environment.
  • Articles 5, 7, and 8 support the additional export assessment content, filing of the report with the contract, and reassessment when specified facts change.
PRC Personal Information Protection Law
cac.gov.cn3 citations
Referenced sections
  • Binding source for PIPIA triggers, required analysis, processing records, and the minimum three-year retention period.
  • Articles 55-56 identify every PIPIA trigger, the three required assessment topics, and the minimum three-year retention period.
  • Article 56 supplies the mandatory assessment content and requires the assessment report and processing record to be kept for at least three years.

Related guides

How should vendor contracts handle entrusted processing under PIPL?

A PIPL entrusted-processing contract must define the purpose, duration, method, personal-information categories, safeguards, and both parties' duties. See the required terms and supporting records.

Is PIPL the same as GDPR?

No. China's PIPL and the EU GDPR overlap on core privacy controls, but differ in territorial scope, legal bases, roles, sensitive data, impact assessments, and transfer routes.

What counts as sensitive personal information in China?

PIPL uses a harm-based test for sensitive personal information and lists examples such as biometrics, health, financial accounts, location traces, and all personal information of children under 14.

What is separate consent under PIPL?

Separate consent under China's PIPL is a distinct consent for a specified processing activity. See when it applies, what notice must come first, and what evidence to keep.

What should an app collect as necessary personal information in China?

Use China's 2021 category rules to identify necessary information for an app's basic function. Keep that function available when users decline non-necessary data.

When can a company use the China standard contract route?

Use China's standard contract route only after applying the 2024 exemptions and confirming that no CAC security assessment is required. See current thresholds, filing steps, and change triggers.

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