A handler processing personal information of more than 10 million people must conduct an audit at least once every two years.
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10mPeriodic audit threshold 1mProtection officer EventRegulator-required audit 15dRectification report
Evidence · 06 Editorial guide
Algorithm Filing, Generative AI Launch and Content Labelling Evidence
A policy PDF is not a programme. The 2025 audit measures turn PIPL governance into a testable evidence file covering lawful bases, notices, contracts, rights, security, incidents, impact assessments and transfers.
First job List the evidence that would explain processing and transfers — not a policy slogan.
Decision railservice type → public-facing? → filing/assessment → labels → records → change control
See routing factsStart here
Key considerations
The first questions are about urgency, governance and preservation — before collection expands or interviews begin.
- What inventory exists?
- Which audit trigger and review period apply?
- Can each control be tied to current operating evidence and a remediation owner?
Direct answer
What this page decides
Owner
02
02
This page owns the evidence pack for AI01 filing, AI02 generative launch, and AI03 labelling. Covered public-facing recommenders and generative services can trigger filing, security assessment, algorithm description, self-assessment and change/re-filing. Labelling (explicit/implicit) is a provider/platform duty overlay. Enterprise-only tools may be out of a public-filing path — confirm current CAC rules, do not guess. This is not copyright advice (IP) and not a VATS licence (FDI).
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| Public recommender or generator? | Filing/assessment more likely. | Current CAC instruments. |
| Only internal enterprise? | May be a different path. | Do not skip PIPL. |
| Need the label on output? | AI03. | Labelling SOP on this page. |
Scope
What this page owns — and what it does not
AI01–AI03 evidence.
Parent remains Data programme L4.
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| Classify the service | Public vs enterprise, recommender vs generator | Current CAC scope | In/out memo |
| If in: assemble filing/assessment pack | Description, self-assessment, security | No invented form list | Pack |
| Labelling SOP | Explicit/implicit, metadata, user alteration | Provider vs platform | Label rules |
| Change and incident | Model updates, complaints | Re-file if required | Log |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Algorithm/service description | Filing | Product | Mismatch with live app |
| Label and watermark SOP | AI03 | Product | Unlabelled deepfakes |
| Supporting digital-compliance guide | Orientation | Legal | Ignoring /china-consumer-digital-compliance-algorithm-pipl |
Common failure points
Where files usually break
Shipping a China-facing generator with no owner for filing or labels.
FAQ
Narrow follow-ups owned by this page
Where is generative AI copyright?
/generative-ai-and-copyright-in-china-where-the-boundaries-of-infringement-lie is an insight. IP L4 owns training-data copyright; this page owns launch/filing evidence.
Decision map
Keep the question bounded.
- InventorySystems, purposes, people, categories, lawful bases, locations, recipients and retention.
- Test the audit perimeterSelf-audit, the two-year cycle for handlers over 10 million people, or a regulator-required professional audit after specified risk or incident triggers.
- Sample and remediateTest design and operation, retain workpapers, assign findings, verify closure and preserve regulator-ready reports.
Regulatory gates
Approvals that can hold signing or closing.
This map does not decide whether a filing is required on your facts.
A handler processing personal information of more than 1 million people must designate a personal-information protection officer responsible for audit work.
Serious rights or security risk, impact on many people, or an event affecting at least 1 million people or 100,000 sensitive-information subjects can trigger a professional audit.
After regulator-required remediation is completed, the rectification report is due within 15 working days.
Curated resources
Open the asset that matches this job.
01
Guide
02PIPL compliance checklist
A structured prompt for processing, vendors and transfer evidence.
Guide
03China data compliance decision guide
National PIPL, transfer and cybersecurity decision desk — not a substitute for a filing pack.
Guide
04Beijing data privacy and cybersecurity lawyers
Local counsel layer when regulator practice is material.
Guide
05Personal Information Protection Compliance Audit Measures
Effective 1 May 2025: periodic and regulator-required audits, professional-institution controls, evidence and remediation reporting.
Guide
Network Data Security Management Regulation
Effective 1 January 2025: network-data security, personal information, important data, platform and incident governance.
Helpful to prepare
Facts that make the next conversation clearer.
These items are orientation aids, not a legal requirement list.
Where the live inventory sitsNamed owner of the transfer fileApplicable audit trigger, review period and last completed audit
Evidence file
Preserve the record before the forum is chosen.
This is a preparation prompt, not a finding that any item is admissible or required.
- Processing inventory
- Vendor and overseas-recipient map
- Transfer mechanism documents
- Notice and request handling notes
- Incident log, if any
- Lawful-basis, notice, consent and sensitive-information matrix
- Joint, entrusted and recipient contracts plus supervision records
- PIPIA register, rights-request log and deletion evidence
- Audit workpapers, findings, remediation owners and closure tests
Counsel hand-off
What to bring when you instruct
Instruct data/cyber counsel. Bring: product description, user geography, and whether output is public.
Local context
Add the city when regulator practice changes.
CAC and industry-regulator practice can differ after the national transfer or cybersecurity question is identified.
Open city and province guidesCounsel hand-off
Need data-privacy counsel?
This hub organises PIPL, cybersecurity and export questions. It does not decide whether a transfer is lawful or whether notice is required on your facts.
Find data-privacy counselLegal review
Who reviewed this guide
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.