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2026-07-03Revised Internet Information Service Measures draft2026-06-18Network data risk assessment: draft versus final

Start with the route decision, not a signature

This guide is for a transfer for which the Chinese standard-contract route has already been identified as available and appropriate. It explains preparation and filing, not a universal permission to export personal information. A commercial data-processing agreement, an EU transfer clause or an intra-group policy does not replace the prescribed Chinese standard contract.

Do not copy the original 2023 numerical conditions into a current route memo without checking later rules. The 2024 provisions expressly address inconsistencies with earlier measures, use a current-calendar-year export count, and preserve exemptions and FTZ arrangements. Assess important data, critical-information-infrastructure status, sensitive information and applicable later or sector-specific rules before this filing workflow. Splitting volumes to avoid a required security assessment is not permitted.

The outputs are different: the route memo explains why this mechanism is available; the impact assessment tests the proposed activity and safeguards; the contract allocates enforceable obligations; the filing record evidences the administrative process. None alone proves that the others are correct.

Seven materials, with a purpose for each

Section III of the national second-edition guide lists seven materials. The checks below are our preparation suggestions, not additional official forms or a substitute for annex 1. Obtain the current official templates from the CAC release and follow the filing system's instructions on signatures, seals and uploads.

MaterialWhat to reconcile before filingSuggested internal owner
Unified social credit code document copyThe filing entity must match the domestic contractual party; distinguish parent, subsidiary and trading name.Corporate administration
Legal representative's identity document copyCheck the identity against current corporate records; protect the copy as personal information.Corporate administration
Filing handler's identity document copyUse the person actually authorized to handle the filing, not an unexplained shared account.Filing coordinator
Authorization for the filing handlerAuthority, entity and handler must agree with the identity documents and submission.Authorized signatory
UndertakingVerify the facts being attested to before signature; a template is not evidence that those facts are true.Responsible business and compliance owners
Standard contractUse the prescribed text and describe the actual transfer. Additional commercial clauses must not conflict with it.Domestic party and overseas recipient
Personal information protection impact assessment reportAssess the same purposes, fields, recipients, retention and safeguards as the executed contract.Assessment owner with technical evidence

Three clocks that must not be confused

Articles 6–7 of the Measures distinguish contract effectiveness from filing. Transfers under this route may take place only after the standard contract becomes effective; the filing must be made within ten working days from that effectiveness. The later filing deadline is not permission to transfer before effectiveness, and a filing number is not a general regulatory endorsement of the business.

The national guide then gives the provincial authority a materials-check period and the processor a separate supplementation period. Use working days, not a ten- or fifteen-calendar-day reminder. Preserve system receipts and authority requests, and confirm the holiday calendar and any case-specific deadline with the receiving authority. The sequence below does not promise an end-to-end completion date.

EventPublished timingRecord to preserve
Contract becomes effectiveFile within 10 working days from effectiveness.Executed version, effectiveness evidence, submission receipt.
Authority checks submitted materials15 working days from submission under the national guide.Submission identifier, feedback and filing number if issued.
Supplementation requestedSubmit the requested supplement within 10 working days; delay may terminate this filing.Request, point-by-point response and resubmission receipt.
Supplementary or new filingThe guide specifies a 15-working-day materials check.New assessment, contract changes and linked filing history.

Make the contract and PIPIA describe one activity

Article 5 requires an assessment of legality and necessity, information scale and sensitivity, recipient capability, security risks, rights channels and the effect of the recipient jurisdiction's rules. A generic corporate privacy policy cannot answer those questions for a specific transfer. The original cross-check below turns them into a document review that business, legal and technical staff can perform together.

Compare across documentsEvidence questionExample of a mismatch
Purpose and scopeDoes each exported field support the stated activity?Contract says support; assessment also assumes marketing use.
Recipient and onward handlingWho can actually access the data, including support staff?One recipient named; a second group company receives access.
Scale and sensitivityCan counts and classifications be reproduced from an inventory?Account totals substituted for people; health fields omitted.
Retention and deletionDo contract commitments match live systems and backups?One-year retention promised; backups remain for three years.
Safeguards and individual rightsWho implements each control and handles overseas requests?A named deletion process has no responsible team or tested workflow.

Treat filing as a maintained record

Article 8 is not limited to replacing the overseas recipient. It covers changes to purpose, scope, categories, sensitivity, method, storage location, the recipient's purposes or methods, or an extension of overseas retention. Changes in the recipient jurisdiction's protection rules, and other circumstances affecting personal information rights, also require review. For covered changes, reassess, supplement or re-execute the standard contract, and carry out the corresponding filing procedure.

Create a change log before a release or vendor amendment, not after the annual review. Record the old facts, proposed facts, affected contract and assessment passages, decision owner and filing action. The guide distinguishes supplemental materials for a supplementary contract from a new filing for a re-executed contract; it does not make every IT ticket a new filing.

Hypothetical example: a Shanghai processor's filed support service keeps ordinary contact records for twelve months. The supplier proposes thirty-six months and adds a new overseas analytics use. This is not simply a price renewal: retention and purpose have changed. Revisit necessity, access and deletion evidence, perform the required reassessment and contractual/filing steps, and do not treat the original filing as covering the new arrangement automatically.

National guide, local instructions and version history

The CAC released the first edition on 30 May 2023 and the second on 22 March 2024. The second-edition release explicitly adds the online data-export submission system and says materials were optimized and simplified. The guide should be read with the 2024 changes to route conditions. This article does not claim a line-by-line redline of all five annexes or identify unverified form deletions.

Do not merge a province's extra requirements into the national seven-item list. For example, Tianjin's separate local instruction lists other supporting evidence in addition to the seven categories. It is local guidance for Tianjin, not proof that an eighth item is universally required. Check the processor's receiving authority and its current procedural instructions before submission.

A practical handoff checklist

Give one coordinator the final version set: route memo, dated assessment, signed contract, identity and authority materials, evidence index and submission log. Ask a reviewer who did not draft the package to compare party names, categories, counts, dates and retention across documents. Keep earlier working copies distinct from the versions actually filed.

Limit access to identity documents and assessment exhibits, record who submitted them, and route feedback to named owners. A confirmation screen is an administrative record, not a reason to stop maintaining safeguards. Keep monitoring changes to the transfer and the official guidance after the filing is complete.

Official sources & revisions

: Expanded the existing guide with a seven-material review matrix, distinct filing clocks, a contract/PIPIA cross-check, a hypothetical change case and national/local source boundaries. The national guide body was checked through the official Tianjin republication; this is not a full annex redline.

Examples and working tables are original research aids, not official forms or legal advice.

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