Filed under data-security
Every brief tagged "data-security".
- § 01 · IMPORTANT-DATA
Are You Caught by the Annual Assessment? TRIMPS's Self-Identification Guide for 'Important-Data Handlers'
With the Network Data Security Risk Assessment Measures (Order No. 24) taking effect August 20, 2026, the annual risk-assessment duty stops being a principle and becomes a hard calendar event — but only for 'important-data handlers' (重要数据处理者). DCC's summary of a self-identification guide from the Data Security R&D Center of the Ministry of Public Security's Third Research Institute (公安部三所 / TRIMPS), author Lü Mingxuan, walks the threshold test the institution that helps draft the standards wants processors to run before the clock starts. There are three independent gates, any one of which puts you in: (1) you process data meeting the 'important data' definition under Article 62 of the Network Data Security Management Regulation; (2) the deeming rule — you process the personal information of more than 10 million people, which pulls you into the important-data duties of Regulation Arts. 30 and 32 regardless of whether you hold any 'important data'; or (3) your data sits on a regional, departmental, or sectoral important-data catalogue. Entrusted processors inherit the duty from an important-data-handler client; CIIO status and important-data-handler status are separate, intersecting tests; and identifying important data runs through GB/T 43697-2024 Appendix G's 18 factors plus the applicable catalogues. The guide then lays out the operating requirements once you are in: annual mandatory assessment plus trigger-based instant assessments, a stacked PIPIA for the 10-million-PI cohort, three-year report retention, and submission within 20 working days. DCC's read for overseas counsel: classification is the gate, the 10-million-PI deeming rule is the trap for consumer businesses with no 'important data' at all, and the self-ID needs to happen now.
- § 02 · RISK-ASSESSMENT
From Principle to Running System: How the Network Data Security Risk Assessment Measures Operationalize the Data Security Law
On June 18, 2026 the CAC, MIIT and the Ministry of Public Security jointly issued the Measures for Network Data Security Risk Assessment as Order No. 24, effective August 20, 2026. The 25-article rule adds no new substantive duty; it turns the Data Security Law's open-ended 'conduct risk assessment' obligation into an executable, verifiable, trigger-able governance system. DCC reads it as a three-tier standing model plus an event-driven escalation layer: important-data handlers must assess every year (general-data handlers are encouraged to every three), retain the report for three years and submit it within 20 working days; sectoral competent authorities run annual inspection plans filed by end-January; the national cyberspace administration consolidates and cross-shares reports with telecom, public-security and state-security departments; and where a high-risk finding or a breach of important data or large-scale personal information appears, regulators can compel assessment by a certified institution and order the operator to cease processing important data. The four institutional increments over the DSL: an annual mandatory action, networked multi-department supervision, a three-track assessment structure, and dynamic event-triggered oversight.
- § 03 · CRITICAL-INFORMATION-INFRASTRUCTURE
Are You a CII Operator or an Important-Data Handler? A Practitioner's Assessment Framework Under China's New Rules
China's Cybersecurity Law, Data Security Law, and Network Data Security Management Regulations impose materially heavier compliance obligations on critical information infrastructure (CII) operators (关键信息基础设施运营者) and important-data handlers (重要数据处理者) than on ordinary data processors. This brief, drawing on a DEXC+ practitioner analysis by Gu Qingzhuo (古青卓) of the Shenzhen Data Exchange compliance team, explains how the two statuses are determined under the current framework, why neither is self-evident from a company's own assessment alone, how recent rules — including the Regulations on Promoting and Regulating Cross-Border Data Flows and the national standard GB/T 43697-2024 — have clarified but not fully resolved the important-data identification problem, and what overseas counsel should do when advising clients that operate in China's critical sectors.
- § 04 · SENSITIVE-PERSONAL-INFORMATION
Seven Highlights of China's New Sensitive Personal Information Processing Standard — and What They Mean in Practice
GB/T 45574-2025 《数据安全技术 敏感个人信息处理安全要求》 (Data Security Technology — Security Requirements for Processing Sensitive Personal Information) is China's first dedicated national standard on sensitive personal information (敏感个人信息), effective 1 November 2025. Authored by Wang Yi, Zhao Yanming, and Zeng Lingwei of the Shenzhen Data Exchange DEXC+ program, this brief walks through the seven highlights the standard introduces: a recalibrated scope of what counts as sensitive personal information under PIPL, dynamic classification logic, a new linkage between sensitive-PI volume and the important data threshold, industry-specific and group-specific protections, data-security-maturity requirements, a model written-consent template, and tightened lifecycle obligations covering collection, storage, display, and audit. The operational takeaway for overseas counsel: the standard converts PIPL's high-level sensitive-PI obligations into testable, auditable requirements — compliance teams should treat it as the primary implementation guide for PIPL Article 28 and beyond.