What is the primary objective of **PIPL**?

**PIPL's primary objective is to protect natural persons' personal information rights and interests while regulating handling activities to promote reasonable data use.** Enacted August 20, 2021, and effective November 1, 2021, the law's 74 articles establish principles of lawfulness, necessity, minimization, transparency, accuracy, integrity, confidentiality, and accountability for processing personal information of individuals in China.

Who is legally or professionally required to comply with **PIPL**?

**PIPL requires compliance from all personal information handlers—organizations or individuals—processing data of natural persons within China, with extraterritorial reach to foreign entities providing products/services to or analyzing behaviors of Chinese individuals.** This includes multinationals without China presence, who must appoint a local representative (Article 53); handlers processing PI of over 1 million individuals must designate a Personal Information Protection Officer.

Does **PIPL** require an external audit or third-party certification?

**PIPL does not universally require external audits or third-party certification but mandates them for specific scenarios like large-scale handlers and cross-border transfers.** Handlers of PI for over 10 million individuals must conduct compliance audits at least every two years; cross-border transfers exceeding 1 million individuals' PI or 10,000 sensitive PI require CAC security assessments or certification; PIPIAs are internally required for high-risk processing (Article 55).

How often should an assessment for **PIPL** be performed?

**PIPL requires regular internal assessments, with PIPIAs conducted before high-risk processing and compliance audits at least every two years for handlers of over 10 million individuals' PI.** Ongoing monitoring includes periodic security audits, incident response testing, and updates to data inventories; records must be retained for at least three years.

What are the consequences of non-compliance with **PIPL**?

**Non-compliance with PIPL incurs administrative fines up to RMB 50 million or 5% of prior-year global annual revenue for grave violations, plus personal fines up to RMB 1 million for responsible executives.** Additional penalties include business suspension, license revocation, corrective orders, and civil liability with burden-shifting to prove lawfulness; criminal penalties apply to severe cases like large-scale sensitive PI trafficking.

Can **PIPL** be mapped to other international frameworks?

**Yes, PIPL can be mapped to other international frameworks through shared principles like data minimization, accountability, and impact assessments, though differences exist in legal bases and cross-border rules.** Organizations align controls such as ISO 27001 security measures and GDPR-like rights handling, but must address PIPL-specific consent defaults, SPI definitions, and CAC security reviews absent in frameworks like GDPR's legitimate interests basis.

What is the first step to begin implementing **PIPL**?

**The first step for PIPL implementation is conducting a comprehensive gap analysis and data mapping to inventory PI flows, classify sensitive personal information, and identify processing purposes.** This Phase 1 effort produces a data register, risk heatmap, and remediation roadmap, securing executive sponsorship to prioritize high-risk areas like SPI and cross-border transfers.

What is the primary objective of **AS9110C**?

**AS9110C's primary objective is to enable aviation maintenance organizations to consistently provide products and services meeting customer and statutory/regulatory requirements while enhancing satisfaction through effective QMS application and continual improvement.** It incorporates ISO 9001:2015's Annex SL structure (Clauses 4–10) with maintenance-specific additions like configuration management, product safety, counterfeit parts prevention, traceability, preservation, and human factors controls to ensure continuing airworthiness.

Who is legally or professionally required to comply with **AS9110C**?

**AS9110C applies to organizations providing maintenance, repair, overhaul (MRO), and continuing airworthiness services for civil and military aircraft, regardless of size.** Target entities include repair stations, independent MRO providers, OEMs with autonomous MRO operations, and component overhaul facilities. Certification is often contractually required by OEMs, airlines, and regulators for OASIS listing and supply-chain access, though not legally mandated absent specific approvals.

Does **AS9110C** require an external audit or third-party certification?

**Yes, AS9110C requires third-party certification via accredited bodies following Stage 1 (documentation review) and Stage 2 (implementation audit).** The QMS must be fully operational for at least three months, including a full internal audit cycle and management review, before initial certification. Ongoing surveillance audits occur annually, with recertification every three years.

How often should an assessment for **AS9110C** be performed?

**Internal audits for AS9110C must be performed at planned intervals based on process risk, status, and results, with a full cycle covering all processes before certification.** Management reviews occur regularly (e.g., annually or semi-annually), using performance data from monitoring, audits, and nonconformities. High-risk processes like configuration management and release warrant more frequent assessments.

What are the consequences of non-compliance with **AS9110C**?

**Non-compliance with AS9110C risks loss of certification, exclusion from contracts, regulatory sanctions, and safety incidents compromising airworthiness.** It can lead to OEM/airline de-listing from OASIS, repair station approval revocation (e.g., FAA/EASA Part 145), rework costs, AOG events, litigation, and reputational damage from latent defects or counterfeit parts.

Can **AS9110C** be mapped to other international frameworks?

**Yes, AS9110C aligns directly with ISO 9001:2015 via its Annex SL high-level structure and shares terminology like "documented information" and "external providers."** IAQG correlation matrices facilitate mapping to regulatory frameworks such as FAA/EASA Part 145, enabling integrated QMS without exclusions where requirements apply within scope.

What is the first step to begin implementing **AS9110C**?

**The first step is to define the QMS scope, determine internal/external issues (Clause 4), and conduct a gap analysis against Clauses 4–10 using IAQG checklists.** Secure executive sponsorship, map regulatory approvals (e.g., licenses, ratings), and justify any non-applicable requirements to ensure full applicability where feasible.

PIPL vs AS9110C

Standards Comparison

PIPL

Mandatory

2021

China's comprehensive law for personal information protection

AS9110C

Mandatory

2016

International standard for aviation maintenance quality management.

Quick Verdict

PIPL mandates data protection for China operations with heavy fines, while AS9110C certifies aerospace MRO quality voluntarily. Companies adopt PIPL for legal compliance and market access; AS9110C for contracts, safety, and supplier qualification.

Data Privacy

PIPL

Personal Information Protection Law (PIPL)

Cost

€€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Extraterritorial reach to processors targeting Chinese individuals
Explicit separate consent for sensitive personal information
Cross-border transfers via security reviews or SCCs
Fines up to 5% of annual revenue
Mandatory impact assessments for high-risk processing

Quality Management

AS9110C

AS9110C: Quality Management Systems Requirements for Aviation Maintenance Organizations

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Risk-based thinking in strategic and operational planning
Configuration management and product traceability
Counterfeit and suspect parts prevention controls
Human factors in root cause analysis
Continuing airworthiness and maintenance release requirements

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

PIPL Details

What It Is

Personal Information Protection Law (PIPL) is China's comprehensive national regulation enacted in 2021, governing collection, processing, storage, transfer, and deletion of personal information. It applies domestically and extraterritorially to organizations handling data of Chinese individuals. PIPL adopts a risk-based approach with strict consent defaults, modeled partly on GDPR but emphasizing national security and data localization.

Key Components

Core principles: lawfulness, necessity, minimization, transparency, accountability.
Seven legal bases, prioritizing consent; no broad legitimate interests.
Sensitive personal information (SPI) rules, individual rights (access, deletion, portability).
Cross-border mechanisms: security assessments, SCCs, certification. Compliance enforced by CAC with fines up to 5% revenue.

Why Organizations Use It

Mandatory for China-exposed firms to avoid penalties, disruptions.
Builds trust, enables market access, reduces breach risks.
Strategic advantages in operations, talent, M&A.

Implementation Overview

Phased framework: gap analysis, policies, controls, audits (6-12 months). Applies to all sizes, industries targeting China; requires PIPOs, representatives for foreigners. No formal certification but ongoing audits.

AS9110C Details

What It Is

AS9110C (AS9110:2016 Rev C) is a certification standard for quality management systems (QMS) in aviation maintenance organizations, including repair stations and MRO providers. It builds on ISO 9001:2015 with Annex SL structure, emphasizing risk-based thinking, PDCA cycle, and aviation-specific controls for continuing airworthiness.

Key Components

Core clauses 4–10 covering context, leadership, planning, support, operation, evaluation, improvement.
Aviation additions: configuration management, counterfeit parts prevention, human factors, traceability, preservation.
No fixed control count; focuses on documented information and process approach.
Voluntary certification via IAQG OASIS database.

Why Organizations Use It

Meets customer/OEM contracts and regulatory alignment (FAA/EASA Part 145).
Mitigates safety risks, ensures traceability, boosts on-time delivery.
Enhances market access, customer satisfaction, operational efficiency.
Builds stakeholder trust through auditable evidence.

Implementation Overview

Phased: gap analysis, process design, training, audits, certification (6-12 months typical).
Applies to MROs of all sizes globally; requires internal audits, management review before Stage 2 audit.

Key Differences

Aspect	PIPL	AS9110C
Scope	Personal data protection, processing, transfers	Aerospace MRO quality management, airworthiness
Industry	All sectors handling Chinese data, extraterritorial	Aviation maintenance organizations worldwide
Nature	Mandatory national law, CAC enforcement	Voluntary certification standard, IAQG
Testing	DPIAs, security reviews, compliance audits	Internal audits, certification audits, surveillance
Penalties	Fines to 5% revenue, business suspension	Loss of certification, contract ineligibility

Scope

PIPL

Personal data protection, processing, transfers

AS9110C

Aerospace MRO quality management, airworthiness

Industry

PIPL

All sectors handling Chinese data, extraterritorial

AS9110C

Aviation maintenance organizations worldwide

Nature

PIPL

Mandatory national law, CAC enforcement

AS9110C

Voluntary certification standard, IAQG

Testing

PIPL

DPIAs, security reviews, compliance audits

AS9110C

Internal audits, certification audits, surveillance

Penalties

PIPL

Fines to 5% revenue, business suspension

AS9110C

Loss of certification, contract ineligibility

Frequently Asked Questions

Common questions about PIPL and AS9110C

PIPL FAQ

AS9110C FAQ

You Might also be Interested in These Articles...

Top 10 SOC 2 Mistakes Startups Make (and Fixes with Automation)

Avoid top 10 SOC 2 mistakes like scope creep & evidence gaps. See fail/pass visuals, client quotes, Vanta/Drata automation fixes for bootstrapped startups. Quic

What if the EU would not have made GDPR mandatory...

Explore a world without mandatory GDPR: How would organizations manage data? What data privacy regs would emerge? Uncover impacts on businesses and privacy laws

Proving CIS Controls v8.1 Works: A KPI & Evidence Framework for Board Reporting, Audits, and Continuous Assurance

Prove CIS Controls v8.1 effectiveness with KPI catalog, evidence checklist & reporting cadence. Ideal for board reports, audits & cyber-insurance. Measure outco

Run Maturity Assessments with GRADUM

Transform your compliance journey with our AI-powered assessment platform

Assess your organization's maturity across multiple standards and regulations including ISO 27001, DORA, NIS2, NIST, GDPR, and hundreds more. Get actionable insights and track your progress with collaborative, AI-powered evaluations.

100+ Standards & Regulations

AI-Powered Insights

Collaborative Assessments

Actionable Recommendations

Check out these other Gradum.io Standards Comparison Pages

ISO 19600 vs EU AI Act

Compare ISO 19600 vs EU AI Act: Legacy CMS guidelines vs risk-based AI rules. Master governance, risk mgmt & controls to align withdrawn ISO 19600 principles with high-risk AI obligations. Dive in now!

GDPR vs OSHA

Discover GDPR vs OSHA: Contrast EU data privacy law's global reach & fines with US workplace safety standards. Key principles, compliance strategies & enforcement insights. Compare now!

PRINCE2 vs Basel III

PRINCE2 vs Basel III: Compare project governance mastery with banking regs for compliance, risk control & value delivery. Tailor success strategies now!

PIPL

AS9110C

Quick Verdict

PIPL

Key Features

AS9110C

Key Features

Detailed Analysis

PIPL Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

AS9110C Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

PIPL FAQ

What is the primary objective of PIPL?

Who is legally or professionally required to comply with PIPL?

Does PIPL require an external audit or third-party certification?

How often should an assessment for PIPL be performed?

What are the consequences of non-compliance with PIPL?

Can PIPL be mapped to other international frameworks?

What is the first step to begin implementing PIPL?

AS9110C FAQ

What is the primary objective of AS9110C?

Who is legally or professionally required to comply with AS9110C?

Does AS9110C require an external audit or third-party certification?

How often should an assessment for AS9110C be performed?

What are the consequences of non-compliance with AS9110C?

Can AS9110C be mapped to other international frameworks?

What is the first step to begin implementing AS9110C?

You Might also be Interested in These Articles...

Top 10 SOC 2 Mistakes Startups Make (and Fixes with Automation)

What if the EU would not have made GDPR mandatory...

Proving CIS Controls v8.1 Works: A KPI & Evidence Framework for Board Reporting, Audits, and Continuous Assurance

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

ISO 19600 vs EU AI Act

GDPR vs OSHA

PRINCE2 vs Basel III