On 3 April 2026 China’s Cyberspace Administration (CAC) published a draft regulation titled the Provisions on Simplified Measures for Personal Information Protection by Small Personal Information Controllers (Draft for Comment) (the „Draft“). The Draft is open for public comment and, once finalized, will introduce a tiered compliance framework under China’s Personal Information Protection Law (PIPL). […]
Han Zhang
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China’s Face Recognition Regulation: What the New Rules Mean for Businesses
On 1 June 2025, China’s Cyberspace Administration (CAC) brought into force the Measures for the Security Management of Face Recognition Technology Applications (the „Measures“). This landmark regulation is the first piece of dedicated legislation in China governing the use of biometric facial data, and it carries significant implications for any organization processing face recognition data […]
China’s 2025 Personal Information Protection Campaign – App Enforcement Takeaways
As 2025 comes to a close, China’s personal information protection enforcement continues to demonstrate sustained intensity and increasing sophistication. Regulatory activity over the past year confirms that personal data protection compliance has become a long-term supervisory priority, characterized by frequent enforcement actions, expanding coverage, and closer scrutiny of actual implementation. In March 2025, the Cyberspace […]
China’s Revised Cybersecurity Law: Key Changes and Compliance Implications
On 28 October 2025, the Standing Committee of the 14th National People’s Congress adopted the Decision on amending the Cybersecurity Law of People’s Republic of China. The revised Cybersecurity Law (the “Revised Law”) will take effect on 1 January 2026. This is the first substantial update to the Cybersecurity Law (“Original Law”) since its promulgation […]
China Issues Measures on Personal Information Compliance Audits
On 14 February 2025, the Cyberspace Administration of China (CAC) issued the Administrative Measures on Compliance Audits for Personal Information Protection (the Measures), which has come into effect on 1 May 2025. The Measures mark the transition of the personal information compliance audit regime, first established under the Personal Information Protection Law of the People’s […]
Understanding China’s new Measures for the Certification of Personal Information Protection for Overseas Transfers
The Personal Information Protection Law and the Network Data Security Management Regulation, among other laws and regulations, stipulate the methods for transferring personal information overseas, including: a data transfer security assessment, a standard contract, and certification. Additionally, other conditions may permit the personal information overseas transfer. Recently, the Cyberspace Administration of China (“CAC”) released the […]
Understanding China’s Network Data Security Management Regulation: Key Comparisons with GDPR and PIPL
After years of development, People’s Republic of China (“China”) has established a data security legal framework centered on the “Cybersecurity Law”, “Data Security Law”, and “Personal Information Protection Law” (PIPL). The issuance of the “Network Data Security Management Regulation” (“the Regulation”) by the State Council coordinates the implementation of the data security management requirements stipulated […]
Biometric Data and GDPR Compliance – a Case Analysis
The growing use of biometric systems in workplaces has brought new challenges for data protection, especially with the General Data Protection Regulation (GDPR) in Europe. A recent case in Belgium highlights these issues after a company introduced a fingerprint-based time-tracking system without properly adhering to GDPR rules. Facts In 2020, a Belgian company began using […]