Disclaimer: This guide is intended for informational purposes only and does not constitute legal advice. Chinafy is not a legal or corporate advisory entity. Given that legal obligations vary by business type and context, we recommend consulting with qualified legal counsel for advice specific to your organization. If needed, Chinafy can connect you with one of our experienced legal partners.

What is the Personal Information Protection Impact Assessment (PIPIA)?

The Personal Information Protection Impact Assessment (PIPIA) is a mandatory risk-assessment process required by China’s Personal Information Protection Law (PIPL). It helps organizations:

Verify that their handling of personal information (PI) is lawful, ethical, and proportionate

Ensure that risks to individuals are identified and controlled.

Who needs to conduct a PIPIA?

Companies (referred to as "personal information handlers" or "PI handlers" under PIPL) are required to carry out and document a PIPIA for certain processing activities (see list below). This applies to almost all companies based in China, especially those handling sensitive personal information or involved in cross-border data transfers.

The assessment can be performed by:

Internal teams with China-specific privacy, cybersecurity, or legal expertise, or

External specialists such as data‑protection consultants.

While the PIPL and GDPR have some overlaps, it’s important to note the regulatory requirements differ.

When do companies need to conduct a PIPIA?

Companies that are processing personal information have to conduct a PIPIA before engaging in data processing that involves:

Cross-border transfers

Sensitive PI (e.g., biometrics, health, financial data, or data of minors under 14).

Automated decision-making (use of personal data in algorithm-driven systems).

Third-party sharing, such as for encryption, access controls and secure storage practices.

Launching new products/services that involve processing PI or making significant changes to data processing.

Potential exclusions

Small-scale data processing: Organizations handling personal information of a limited number of individuals (thresholds may also take into account the type of data and associated risks) may not need to conduct a full PIPIA, though they must still comply with basic PIPL obligations.

Non-sensitive data: Processing non-sensitive personal information that does not involve high-risk activities (e.g., basic contact details for non-commercial purposes) may not trigger a PIPIA requirement, provided it poses minimal risk to individuals.

Intra-company processing: Data processing activities that occur entirely within a single organization (e.g., internal employee data management) and do not involve third-party sharing or cross-border transfers may be exempt, unless sensitive data or automated decision-making is involved.

Government exemptions: Certain activities conducted by public authorities or state institutions for national security, public interest, or legal compliance may be exempt from PIPIA requirements, as specified in PIPL Article 35.

Previously assessed activities: If a PIPIA has already been conducted for a similar processing activity and no significant changes have occurred in the data processing methods, purposes, or risks, a new PIPIA may not be required.

Note: Exemptions are context-specific. Companies should consult with legal experts to confirm whether their specific data processing activities qualify for any exemptions under PIPL. If needed, Chinafy can connect you with one of our experienced legal partners.

How to conduct a PIPIA

The exact approach for conducting a PIPIA will vary for every business, but most assessments follow these general steps:

Scope: Define data flows, the types of personal information, processing purposes, methods, and involved parties.

Legality assessment: Confirm whether the purposes and methods for processing PI are lawful, legitimate and necessary.

Risk mapping: Identify all potential privacy risks associated with the processing activity, such as data breaches, unauthorized access, misuse or inaccurate data handling.

Risk assessment: Evaluate risks based on their likelihood and impact, considering factors like data sensitivity, number of individuals affected and potential harm.

Mitigation: Design controls to reduce identified risks, such as encryption, access controls, staff training and internal policies.

Monitor and review: Schedule ongoing monitoring of privacy risks and the effectiveness of mitigation measures to accommodate changes in processing activities or the legal landscape.

Documentation: Keep clear records of findings, decisions, and controls. You may need these if supervisory authorities request a report.

What’s included in a PIPIA report?

In line with the steps above, the PIPIA report needs to include the following:

A description of each PI processing activity and system.

Confirmation that purposes and methods are lawful, legitimate, and necessary.

Analysis of the impact on individual rights and any security risks.

Details of protection measures and evidence that they match the level of risk.

The volume, scope, type, and sensitivity of PI processed or transferred.

For cross‑border transfers: the overseas recipient’s obligations, safeguards, and the local regulatory landscape.

Organizational details such as corporate structure, data centers, cloud solutions, and network paths.

An attestation that PIPIA records will be retained for at least three years.

Chinafy collaborates with specialized partners, such as Lianwei Pancloud and MS Advisory, who can offer insight into specifics related to your company, regulatory trends and compliance considerations.

Get in touch with Chinafy today to better understand the next steps for your company’s website and data in China.