PrivacyChina

China Privacy Law PIPL impact assessment template

Template fields for a China personal information protection impact assessment and export/entrusted-processing evidence.

Use this working template before sensitive-information processing, automated decision-making, entrustment, provision or disclosure, overseas transfer, or another activity with a major effect on individual rights.

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Author

Sorena AI

Published

Jul 5, 2026

Updated

Jul 24, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Jul 5, 2026

Updated Jul 24, 2026

Overview

Complete and approve a before processing sensitive personal information, using personal information for automated decision-making, entrusting processing, providing personal information to another processor, publicly disclosing it, transferring it overseas, or carrying out another activity with a major effect on individual rights. This is a working record, not an official CAC form. It must show the actual processing, the Article 55 trigger, legality, legitimacy, necessity, effects on individuals, security risks, safeguards, remaining risk, and the decision to proceed, change, or stop.

Section 1

1. Assessment identity, trigger, and scope

Assign the assessment to the personal information processor responsible for the activity. Name a business owner, privacy or legal reviewer, security reviewer, control owners, approver, and review date. One assessment may cover a defined processing activity, but it should not combine unrelated purposes or systems so broadly that the risks and controls cannot be checked.

Assessment ID and version: stable identifier, status, owner, approver, creation date, approval date, and linked processing record.
Article 55 trigger: sensitive personal information; automated decision-making; entrustment; provision to another processor; public disclosure; overseas provision; or another activity with a major effect on individual rights.
Processing scope: product or service, systems, user groups, jurisdictions, start date, purpose, operations, frequency, scale, personal information categories, sensitive categories, sources, recipients, access locations, onward provision, storage, retention, and deletion.
People affected: identify children under 14, employees, patients, customers, or other groups whose circumstances change the likely effect or required controls.
Related decisions: link the processing basis, notice, consent or separate-consent design, vendor role analysis, automated-decision controls, export route, and any required security self-assessment.

Sources for this answer

PRC Personal Information Protection Law

Article 55 lists the activities requiring a prior impact assessment and a processing record; Articles 20-31 and 38-40 provide context for the selected trigger.

Section 2

2. Legality, necessity, effects, and risks

Article 56 sets three required assessment subjects. The record should answer each one with facts and linked evidence rather than a pass or fail label.

Legality and legitimacy: identify the PIPL processing basis, applicable notice and consent requirements, purpose limits, recipient or vendor role, individual-rights route, and any sector rule or authorization that affects the activity.
Necessity: explain why the purpose is specific and reasonable, why each category and operation is directly related to it, whether less data or a less intrusive method would work, and why the retention period is the shortest necessary unless another law sets it.
Effects on individuals: assess loss of control, denial of service or opportunity, unfair or opaque automated outcomes, discrimination, embarrassment, identity or financial harm, surveillance, physical-safety risk, and added effects on children or other affected groups.
Security risks: cover unauthorized access, excessive privilege, insecure transfer or storage, re-identification, misuse, alteration, loss, leakage, recipient failure, vendor or onward-transfer risk, incident detection, and inability to fulfill individual rights.
Risk record: for each credible scenario, record cause, affected information and people, likelihood and effect rationale, existing safeguards, control owner, evidence, planned action, deadline, and remaining risk after treatment.

Sources for this answer

PRC Personal Information Protection Law

Article 56 requires analysis of legality, legitimacy, necessity, effects on individual rights, security risks, and whether safeguards are lawful, effective, and proportionate.

Section 3

3. Safeguards, decision, and retention

For each material risk, test whether the proposed protection measure is lawful, works in the actual system and operating process, and matches the level of risk. Name the evidence that proves implementation, such as configuration, access review, test result, contract, deletion record, incident exercise, or rights-request test.

Decision: approve, approve with conditions, redesign, or stop. Record unresolved issues, conditions, owners, deadlines, and who accepted any remaining risk within the organization's authority.
Pre-start gate: do not begin the assessed activity until required controls, notices, consents, contracts, recipient reviews, and export steps are complete.
Retention: keep the impact assessment report and processing record for at least three years. A longer period may follow from another applicable duty or the need to evidence an ongoing activity.
Change review: reassess before a material change to purpose, method, personal information, sensitivity, scale, affected group, algorithm, vendor, recipient, destination, access model, retention, legal environment, or safeguard.
Operational review: connect incidents, complaints, rights requests, audit findings, model or system monitoring, vendor reviews, and control failures back to the assessment.

Sources for this answer

PRC Personal Information Protection Law

Article 56 establishes the safeguards test and minimum three-year retention; Articles 51 and 57 support security controls and incident handling.

Measures for the Standard Contract for Personal Information Export

Articles 5 and 8 add export-specific assessment subjects and reassessment triggers when the standard-contract route is used.

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Primary sources

References and citations

Measures for Security Assessment of Data Export

cac.gov.cn

Referenced sections

Separate data-export risk self-assessment requirements where a CAC security assessment is required; this filing assessment does not replace the PIPL impact assessment.

Measures for the Standard Contract for Personal Information Export

cac.gov.cn

Referenced sections