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China Privacy Law PIPL privacy notice and consent checklist

Checklist for PIPL privacy notices, valid consent, , sensitive information, children under 14, withdrawal, and rights requests.

Give the before processing, then match each consent request to the specific activity. Consent is not required under PIPL when another Article 13 condition is the documented basis.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections2 primary sources
Overview

Give a prominent, clear, accurate, and complete before processing. If consent is the Article 13 basis, the person must act voluntarily and explicitly after being fully informed. Where consent is the processing condition, is an additional, activity-specific consent for the PIPL situations that expressly require it; a general privacy-policy acceptance should not be treated as proof of every separate-consent decision.

Section 1

Build the notice around the real processing

Name the personal information processor and give its contact details. For each purpose, state the processing method, personal-information categories, retention period, and the method and procedure for exercising PIPL rights. Make the rules public and easy to consult and save.

A general notice is not enough for every special activity. Add the recipient's identity, contact details, purpose, method, and data categories before providing personal information to another independent processor. For an overseas recipient, also explain how the person can exercise PIPL rights against that recipient. For sensitive personal information, explain why processing is necessary and how it may affect the person's rights.

  • Content owner: use specific purposes and data categories rather than open-ended phrases. State the shortest necessary retention period unless a law or administrative regulation sets another period.
  • Product owner: show the notice before collection or other processing, and keep it accessible after the interaction.
  • Change owner: tell people when an item changes. If consent is the basis and the purpose, method, or personal-information categories change, obtain new consent before the changed processing.
  • Exception owner: document any Article 18 notice exception. If an emergency made timely notice impossible, give notice promptly after the emergency ends.
Section 3

Run the launch and change checks

Review each screen and processing event against the data map, not only the published policy. A notice can be accurate while the product collects a different field, sends data to an undisclosed recipient, keeps it longer, or fails to apply withdrawal.

Complete a personal information protection impact assessment (PIPIA) before processing sensitive information, using personal information for automated decision-making, entrusting processing, providing information to another processor, publicly disclosing information, exporting information, or carrying out other processing with a major effect on individual rights. Keep the PIPIA report and processing record for at least three years.

  • Before launch: reconcile purposes, data categories, software development kit (SDK) and vendor flows, retention, recipient roles, consent triggers, sensitive-information controls, and rights channels.
  • After launch: test notice visibility, consent-state enforcement, withdrawal, deletion, recipient restrictions, and treatment of users who refuse optional processing.
  • On change: reopen the notice and consent analysis when a purpose, method, data category, recipient, retention period, or overseas destination changes.
  • For apps: do not deny a basic function because the user refuses personal information that the official app-category rules do not identify as necessary for that function.
Put the requirement into practice

Prepare the notice and consent evidence file

Assign owners, implement controls, and keep the notice, consent, withdrawal, and rights evidence together.

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 notice content, processing conditions, consent and withdrawal, separate-consent triggers, sensitive information, children's information, rights, and PIPIA.
  • Articles 17-19, 23, 30, and 39 specify general notice content, notice exceptions, retention, recipient disclosures, sensitive-information notice, and overseas-recipient notice.
  • Articles 13-16, 23, 25-31, and 44-50 establish processing conditions, valid and renewed consent, withdrawal, separate-consent triggers, children-under-14 rules, and individual rights.
Show 1 more
  • Articles 21, 55, and 56 require pre-processing impact assessments for listed higher-risk activities and retention of the assessment and processing record for at least three years.
Necessary Personal Information Scope for Common Types of Mobile Apps
cac.gov.cn2 citations
Referenced sections
  • Official app-category source for the no-refusal rule and the minimum personal information tied to each listed basic function.
  • Defines necessary personal information for 39 common app categories and prohibits refusal of a basic function when a user declines non-necessary information.

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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.