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China Privacy Law PIPL impact assessment template

Template fields for a China 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
Oct 15, 2026
3 sections3 primary sources
Overview

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, 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.

The named reviewers, approver, internal risk method and sign-off fields are practical governance recommendations. Articles 55-56 require the prior assessment, processing record, stated assessment topics and at least three years of report and record retention; they do not prescribe these internal role titles or a universal approval workflow.

  • 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.
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.
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.
Recommended next step

Complete the assessment before processing

Use the template to record the trigger, processing facts, Article 56 analysis, safeguards, decision, conditions, and review triggers.

Research workflow
Map official sources to evidence

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

Explore next step
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

PRC Personal Information Protection Law
cac.gov.cn4 citations
Referenced sections
  • Binding source for PIPIA triggers, minimum assessment content, processing records, security duties, and minimum three-year retention.
  • 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.
  • Article 56 requires analysis of legality, legitimacy, necessity, effects on individual rights, security risks, and whether safeguards are lawful, effective, and proportionate.
Show 1 more
  • Article 56 establishes the safeguards test and minimum three-year retention; Articles 51 and 57 support security controls and incident handling.
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.

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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 records should we keep for a PIPL impact assessment?

A PIPL impact-assessment file should preserve the Article 55 trigger, processing facts, Article 56 analysis, safeguards, decision, and processing record for at least three years.

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.

When does a China PIPL security assessment apply?

A CAC data export security assessment applies to CIIO exports, important data, and specified high-volume personal-information exports after the 2024 exemptions are applied.