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

Keep the PIPIA 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
Questions
2

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3

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Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
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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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.
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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.
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Prepare the PIPL and data export evidence file

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Map official sources to evidence

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Primary sources

References and citations

PRC Personal Information Protection Law
cac.gov.cn
Referenced sections
  • Article 56 supplies the mandatory assessment content and requires the assessment report and processing record to be kept for at least three years.
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