PIPL
China's comprehensive law for personal information protection
NIST 800-171
U.S. standard for protecting CUI in nonfederal systems.
Quick Verdict
PIPL mandates privacy protections for Chinese personal data with strict consent and transfers, while NIST 800-171 requires CUI security for US contractors via controls and assessments. Companies adopt PIPL for China market access, NIST for federal contracts.
PIPL
Personal Information Protection Law (PIPL)
Key Features
- Extraterritorial scope targeting Chinese individuals abroad
- Consent-first model excluding legitimate interests basis
- Separate explicit consent for sensitive personal information
- Tiered cross-border transfers with volume thresholds
- Fines up to 5% annual revenue or RMB 50M
NIST 800-171
NIST SP 800-171: Protecting CUI in Nonfederal Systems
Key Features
- Protects CUI confidentiality in nonfederal systems
- 110 requirements in 14 families (r2 baseline)
- SSP and POA&M for implementation documentation
- CUI enclave scoping for boundary control
- FedRAMP Moderate equivalence for cloud
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) is China's comprehensive national regulation enacted August 20, 2021, effective November 1, 2021. It governs collection, processing, storage, transfer, and deletion of personal information with extraterritorial reach. Modeled partly on GDPR, it uses a risk-based approach emphasizing individual rights, data minimization, and national security.
Key Components
- Eight chapters, 74 articles covering processing rules, cross-border transfers, individual rights.
- Core principles: lawfulness, necessity, minimization, transparency, accountability.
- Sensitive personal information (SPI) rules, seven legal bases (consent-dominant), Personal Information Protection Impact Assessments (PIPIAs).
- Compliance via governance, audits; no formal certification but CAC security reviews.
Why Organizations Use It
Mandated for entities handling Chinese data; avoids fines up to 5% revenue. Enhances market access, customer trust, operational resilience in China's digital economy. Mitigates breach risks, enables compliant cross-border flows.
Implementation Overview
Phased: gap analysis, data mapping, policies, controls, transfers. Applies to all sizes, industries touching China; MNCs need local representatives. 6-12 months typical, with ongoing audits.
NIST 800-171 Details
What It Is
NIST SP 800-171 (Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations) is a U.S. federal cybersecurity framework. It provides security requirements for safeguarding CUI confidentiality in nonfederal systems, tailored from NIST SP 800-53 Moderate baseline using a control-based, risk-commensurate approach.
Key Components
- 97-110 requirements across 14-17 families (e.g., Access Control, Audit, Configuration Management; r3 adds Planning, Supply Chain Risk Management).
- Built on FIPS 200 and SP 800-53; includes SSP and POA&M for documentation.
- Compliance via self-assessment or third-party audits like CMMC Level 2.
Why Organizations Use It
- Mandatory for DoD contractors via DFARS 252.204-7012.
- Reduces breach risks, ensures contract eligibility, builds supply chain trust.
- Strategic benefits: market access, operational resilience.
Implementation Overview
- Phased: scoping CUI enclave, gap analysis, control deployment, evidence collection.
- Applies to contractors handling CUI; suits all sizes with enclave strategy.
- Assessments use SP 800-171A procedures; ongoing monitoring required. (178 words)
Key Differences
| Aspect | PIPL | NIST 800-171 |
|---|---|---|
| Scope | Personal information processing, cross-border transfers | CUI confidentiality in nonfederal systems |
| Industry | All sectors handling Chinese PI, extraterritorial | US federal contractors, defense supply chain |
| Nature | Mandatory Chinese privacy law, CAC enforcement | Contractual US security requirements, NIST guidance |
| Testing | DPIAs for high-risk, CAC security reviews | SSP/POA&M assessments, CMMC audits |
| Penalties | Up to 5% revenue or RMB 50M fines | Contract loss, ineligibility, no direct fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PIPL and NIST 800-171
PIPL FAQ
NIST 800-171 FAQ
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