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

**PIPL's primary objective is to protect natural persons' personal information rights while regulating processing activities to promote reasonable data use.** Enacted August 20, 2021, and effective November 1, 2021, its 74 articles establish principles of lawfulness, necessity, minimization, transparency, accuracy, integrity, confidentiality, and accountability for personal information handlers (Article 5).

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

**PIPL requires compliance from all personal information handlers processing data of natural persons in China, including extraterritorial entities targeting Chinese individuals.** This covers domestic and foreign organizations providing products/services to or analyzing behaviors of persons in China (Article 3); handlers must appoint China representatives if overseas (Article 53). Applies universally, regardless of size.

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

**PIPL does not mandate external audits or third-party certification for general compliance but requires them for specific high-risk activities.** Handlers of PI from >10 million individuals must conduct compliance audits every two years; >1 million requires a designated responsible person. Cross-border transfers may need CAC security assessments (>1M PI or >10K SPI) or certification (Articles 38-40, 2025 Audit Measures).

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

**PIPL requires Personal Information Protection Impact Assessments (PIPIAs) before high-risk processing, with regular internal compliance audits.** PIPIAs are mandatory for SPI handling, automated decision-making, cross-border transfers, or major-impact activities (Article 55), retained for at least three years. Audits occur at least every two years for >10M PI handlers; ongoing monitoring for all.

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 revenue for grave violations, plus personal liability up to RMB 1 million for managers.** Penalties include business suspension, license revocation, corrective orders, and criminal liability for severe cases (Articles 66-69); e.g., Didi fined RMB 1.2 billion in 2022.

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

**Yes, PIPL can be mapped to other frameworks due to shared principles like data minimization, accountability, and impact assessments, though differences exist in consent primacy and cross-border rules.** Alignments include GDPR-like extraterritoriality and rights; organizations adapt controls for PIPL's lack of "legitimate interests" basis and SPI focus, using gap analyses for hybrid compliance.

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

**The first step for PIPL implementation is conducting a comprehensive gap analysis and data mapping.** Inventory all PI flows, classify general vs. **sensitive personal information** (e.g., biometrics, minors under 14), identify legal bases, and assess cross-border volumes (Phase 1 framework; prioritizes high-risk SPI and CIIO flows).

What is the primary objective of **ISO 27018**?

**ISO 27018 provides a code of practice for protecting **PII** in public clouds acting as **PII processors**.** It extends **ISO 27001**/**ISO 27002** with ~25–30 privacy-specific controls addressing **consent**, **purpose limitation**, **data minimization**, **transparency**, **subprocessor disclosure**, **breach notification**, and **data subject rights** support in multi-tenant environments. The 2025 edition aligns with **ISO 27002:2022**, enabling **CSPs** to demonstrate auditable processor obligations.

Who is legally or professionally required to comply with **ISO 27018**?

**ISO 27018 targets public **CSPs** acting as **PII processors** for customers.** It applies to hyperscalers, regional providers, and sector-specific clouds processing **PII** via multi-tenant services, regardless of size. Controllers use it for vendor due diligence, but it excludes controller-specific duties and private clouds; implementation is risk-based within an **ISMS**.

Does **ISO 27018** require an external audit or third-party certification?

**ISO 27018 requires assessment via external **ISO 27001** audits by accredited bodies under **ISO/IEC 17021** and **ISO/IEC 27006**; no standalone certification exists.** Controls integrate into the **Statement of Applicability**; audits include Stage 1 (documentation) and Stage 2 (effectiveness), with certificates referencing both standards.

How often should an assessment for **ISO 27018** be performed?

**ISO 27018 assessments occur annually via surveillance audits, with full recertification every three years as part of **ISO 27001** cycles.** This ensures ongoing control effectiveness amid cloud changes, including **subprocessor** updates and incident reviews.

What are the consequences of non-compliance with **ISO 27018**?

**Non-compliance with ISO 27018 risks failed **ISO 27001** audits, loss of certification, procurement rejection, and weakened regulatory defense (e.g., **GDPR** Article 28).** It exposes **CSPs** to customer churn, cyber insurance issues, and legal liabilities from **PII** breaches due to gaps in transparency or notification.

Can **ISO 27018** be mapped to other international frameworks?

**Yes, ISO 27018 maps directly to **ISO 27001** Annex A (93 controls), **ISO 27002**, **ISO 27017** (cloud security), and **ISO 27701** (PIMS).** It aligns with **GDPR** processor obligations, **ISO/IEC 29100** principles, and **OECD** guidelines, integrating privacy into security via unified **SoA**.

What is the first step to begin implementing **ISO 27018**?

**Conduct a gap analysis of current **ISMS** against **ISO 27018** controls and **ISO 27001** baseline.** Engage stakeholders to review documentation, **PII** flows, contracts, and risks, producing a prioritized roadmap for remediation within the **Statement of Applicability**.

PIPL vs ISO 27018

Standards Comparison

PIPL

Mandatory

2021

China’s comprehensive law for personal information protection

ISO 27018

Voluntary

2019

International code for PII protection in public clouds.

Quick Verdict

PIPL mandates comprehensive personal data protection for China operations with strict fines, while ISO 27018 offers voluntary cloud PII controls via ISO 27001 audits. Companies adopt PIPL for legal compliance in China; ISO 27018 for trusted cloud procurement.

Data Privacy

PIPL

Personal Information Protection Law (PIPL)

Cost

€€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Extraterritorial application to foreign processors targeting China
Consent-first model without legitimate interests basis
Explicit separate consent for sensitive personal information
Tiered cross-border transfer mechanisms with volume thresholds
Penalties up to 5% annual revenue or RMB 50 million

Cloud Privacy

ISO 27018

ISO/IEC 27018:2025 Code of practice for PII protection

Cost

€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

PII protection controls for public cloud processors
Subprocessor transparency and location disclosure
Prohibits unauthorized PII use like advertising
Mandates customer breach notification procedures
Supports data subject rights fulfillment

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 first comprehensive national regulation on personal information processing, enacted August 2021 and effective November 1, 2021. It governs collection, use, storage, transfer, and deletion of personal data for natural persons in China, with extraterritorial scope for foreign entities targeting Chinese individuals. PIPL uses a risk-based approach, emphasizing consent, data minimization, and national security alongside the Cybersecurity Law and Data Security Law.

Key Components

Core principles: lawfulness, necessity, minimization, transparency, accountability.
Seven legal bases, consent-dominant without broad legitimate interests.
Sensitive personal information (SPI) rules requiring explicit consent.
Cross-border transfers via security assessments, SCCs, or certification.
Individual rights: access, rectification, deletion, portability, ADM explanations. Compliance via CAC enforcement, no formal certification.

Why Organizations Use It

Mandatory for China-exposed firms to avoid fines up to 5% annual revenue.
Enables market access, builds consumer trust, reduces breach risks.
Supports operational resilience, strategic data flows in digital economy.

Implementation Overview

Phased framework: gap analysis, data mapping, governance, controls, audits. Targets multinationals, platforms handling Chinese data; requires DPOs, PIPIAs, ongoing monitoring.

ISO 27018 Details

What It Is

ISO/IEC 27018:2025 is a code of practice extending ISO/IEC 27001 and ISO/IEC 27002 for protecting personally identifiable information (PII) in public cloud services where providers act as PII processors. Its primary scope focuses on cloud-specific privacy risks like multi-tenancy and cross-border data flows. It employs a risk-based approach, adding privacy-specific controls to the ISMS framework.

Key Components

Approximately 25–30 additional privacy controls mapped to ISO 27001 Annex A themes (Organizational, People, Physical, Technological).
Core principles: consent/choice, purpose limitation, data minimization, transparency, accountability.
Built on ISO 29100 privacy framework; assessed via ISO 27001 certification audits, not standalone.

Why Organizations Use It

Builds customer trust and accelerates procurement.
Aligns with GDPR Article 28, HIPAA; aids regulatory compliance.
Mitigates privacy risks, supports cyber insurance.
Differentiates CSPs in competitive markets.

Implementation Overview

Conduct gap analysis against existing ISMS.
Integrate controls into Statement of Applicability, update contracts/training.
Applicable to CSPs of all sizes; requires accredited ISO 27001 audits with 27018 review.

Key Differences

Aspect	PIPL	ISO 27018
Scope	Personal info processing, cross-border transfers, rights	PII protection in public cloud processors
Industry	All sectors handling China data, extraterritorial	Cloud service providers globally
Nature	Mandatory national law with enforcement	Voluntary code of practice, ISO 27001 extension
Testing	CAC security reviews, DPIAs for high-risk	ISO 27001 audits including privacy controls
Penalties	Fines up to 5% revenue, business suspension	Loss of certification, no legal penalties

Scope

PIPL

Personal info processing, cross-border transfers, rights

ISO 27018

PII protection in public cloud processors

Industry

PIPL

All sectors handling China data, extraterritorial

ISO 27018

Cloud service providers globally

Nature

PIPL

Mandatory national law with enforcement

ISO 27018

Voluntary code of practice, ISO 27001 extension

Testing

PIPL

CAC security reviews, DPIAs for high-risk

ISO 27018

ISO 27001 audits including privacy controls

Penalties

PIPL

Fines up to 5% revenue, business suspension

ISO 27018

Loss of certification, no legal penalties

Frequently Asked Questions

Common questions about PIPL and ISO 27018

PIPL FAQ

ISO 27018 FAQ

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PIPL

ISO 27018

Quick Verdict

PIPL

Key Features

ISO 27018

Key Features

Detailed Analysis

PIPL Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

ISO 27018 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?

ISO 27018 FAQ

What is the primary objective of ISO 27018?

Who is legally or professionally required to comply with ISO 27018?

Does ISO 27018 require an external audit or third-party certification?

How often should an assessment for ISO 27018 be performed?

What are the consequences of non-compliance with ISO 27018?

Can ISO 27018 be mapped to other international frameworks?

What is the first step to begin implementing ISO 27018?

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Run Maturity Assessments with GRADUM

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