Standards Comparison

    PIPL

    Mandatory
    2021

    China's comprehensive regulation for personal information protection

    VS

    K-PIPA

    Mandatory
    2011

    South Korea's regulation for personal data protection.

    Quick Verdict

    PIPL enforces strict data protection for China with extraterritorial reach and security reviews, while K-PIPA mandates CPO oversight and 72-hour breach notices for Korea. Companies adopt them for market access, avoiding massive fines up to 5% revenue.

    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Extraterritorial scope targeting individuals in China
    • Explicit separate consent for sensitive personal information
    • Cross-border transfers via security reviews or SCCs
    • Penalties up to 5% annual revenue
    • Mandatory impact assessments for high-risk processing
    Data Privacy

    K-PIPA

    Personal Information Protection Act (PIPA)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Mandatory Chief Privacy Officer appointment
    • Granular explicit consent for sensitive data
    • 72-hour breach notifications to subjects
    • Extraterritorial scope for foreign entities
    • Fines up to 3% of annual revenue

    Detailed Analysis

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

    PIPL Details

    What It Is

    PIPL (Personal Information Protection Law), enacted August 2021 and effective November 2021, is China's first comprehensive national privacy regulation. Modeled partly on GDPR, it governs collection, processing, storage, transfer, and deletion of personal information with extraterritorial scope for entities targeting China. Employs a risk-based, consent-first approach emphasizing lawfulness, necessity, and minimization.

    Key Components

    • **Core principlesLawfulness, propriety, necessity, sincerity, purpose limitation, data minimization, transparency, accuracy, accountability.
    • Seven legal bases led by consent; strict rules for sensitive personal information (biometrics, health, minors under 14).
    • Individual rights: access, correction, deletion, portability, ADM explanations.
    • Cross-border mechanisms: security assessments, SCCs, certifications. Compliance enforced by CAC via audits, no formal certification.

    Why Organizations Use It

    Mandatory for handling China personal data to avoid fines up to RMB 50M or 5% revenue. Enables market access, builds consumer trust, enhances resilience against breaches. Strategic for MNCs in e-commerce, fintech; reduces operational risks.

    Implementation Overview

    Phased framework: gap analysis, data mapping, policies, controls, monitoring. Applies to all sizes handling China data; prioritizes SPI, transfers. Cross-functional, 6-12 months typical; ongoing audits required. (178 words)

    K-PIPA Details

    What It Is

    K-PIPA, or the Personal Information Protection Act, is South Korea's comprehensive data protection regulation enacted in 2011 with major amendments in 2020, 2023, and 2024. It safeguards personal information of Korean residents, including sensitive data like health and biometrics, and unique identifiers such as resident registration numbers. Employing a consent-centric, risk-based approach, it mandates transparency, purpose limitation, and data minimization.

    Key Components

    • Core pillars: explicit consent, security measures, data subject rights (access, erasure, portability), and CPO appointment.
    • Built on principles like accountability and breach notification within 72 hours.
    • No fixed control count; compliance via PIPC enforcement, fines up to 3% revenue.

    Why Organizations Use It

    • Legal mandate for data handlers, domestic and foreign targeting Koreans.
    • Mitigates risks from hefty fines (e.g., Google's $50M penalty).
    • Builds trust, enables EU adequacy data flows, supports AI/innovation via pseudonymization.

    Implementation Overview

    • Phased: gap analysis, CPO setup, consent tools, training, audits.
    • Applies to all sizes processing Korean data; extraterritorial.
    • No certification but PIPC guidelines and voluntary ISMS-P.

    Key Differences

    Scope

    PIPL
    Personal info processing, cross-border transfers, SPI
    K-PIPA
    Personal info handling, sensitive data, unique IDs

    Industry

    PIPL
    All sectors in/out China, multinationals
    K-PIPA
    All sectors in/out Korea, domestic/foreign handlers

    Nature

    PIPL
    Mandatory national law, CAC enforcement
    K-PIPA
    Mandatory national law, PIPC enforcement

    Testing

    PIPL
    PIPIAs for high-risk, CAC security reviews
    K-PIPA
    PIAs for public, CPO audits, no private DPIAs

    Penalties

    PIPL
    RMB 50M or 5% revenue, business suspension
    K-PIPA
    3% revenue or KRW 3B, criminal up to 5 years

    Frequently Asked Questions

    Common questions about PIPL and K-PIPA

    PIPL FAQ

    K-PIPA FAQ

    You Might also be Interested in These Articles...

    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