Filed under data-security
Every brief tagged "data-security".
- § 01 · 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.
- § 02 · 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.