China PIPL compliance checklist
Checklist for PIPL processing activity maps, notices, consent, separate consent, sensitive PI, entrusted processing, export route, and app minimization evidence.
How should vendor contracts handle entrusted processing under PIPL?
Vendor contracts should show entrusted-processing scope, processing purpose, data categories, security duties, assistance with rights/incidents, onward transfer limits, deletion/return, audit evidence, and source references.
Is PIPL the same as GDPR?
No. PIPL and GDPR can support a shared privacy program, but they use different legal concepts, transfer routes, regulatory sources, and evidence requirements. Compare article-by-article before reusing notices, consent flows, or transfer assessments.
What counts as sensitive personal information in China?
Sensitive personal information should be identified from the PIPL source and recorded with purpose, necessity, separate consent analysis, safeguards, retention, and access limits before processing.
What is separate consent under PIPL?
Separate consent is a PIPL-specific consent requirement for certain higher-risk processing situations. The evidence file should identify the trigger, user-facing text, affirmative action, withdrawal path, and source article.
What records should we keep for a PIPL impact assessment?
Keep purpose, processing basis, personal information categories, sensitive PI/minors, entrusted processors, export route, risks, safeguards, retention, rights handling, incident plan, reviewer, and source references.