Standards Comparison

    PIPL

    Mandatory
    2021

    China's comprehensive law for personal information protection

    VS

    NIST 800-171

    Mandatory
    2020

    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.

    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

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

    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
    Controlled Unclassified Information

    NIST 800-171

    NIST SP 800-171: Protecting CUI in Nonfederal Systems

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

    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

    Scope

    PIPL
    Personal information processing, cross-border transfers
    NIST 800-171
    CUI confidentiality in nonfederal systems

    Industry

    PIPL
    All sectors handling Chinese PI, extraterritorial
    NIST 800-171
    US federal contractors, defense supply chain

    Nature

    PIPL
    Mandatory Chinese privacy law, CAC enforcement
    NIST 800-171
    Contractual US security requirements, NIST guidance

    Testing

    PIPL
    DPIAs for high-risk, CAC security reviews
    NIST 800-171
    SSP/POA&M assessments, CMMC audits

    Penalties

    PIPL
    Up to 5% revenue or RMB 50M fines
    NIST 800-171
    Contract loss, ineligibility, no direct fines

    Frequently Asked Questions

    Common questions about PIPL and NIST 800-171

    PIPL FAQ

    NIST 800-171 FAQ

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