General information only. PIPL, data-export security assessment, standard contract, and certification paths depend on volume, sensitivity, industry, and CAC/local practice. This is not legal advice and does not create an attorney–client relationship. Instruct qualified PRC privacy counsel before you connect global HRIS/CRM instances or ship employee files offshore.
MNC China data compliance cluster: Hub · PIPL checklist (US cos) · Employee data outbound · HR / CRM systems · Export path decision · Sensitive localization · SCC filing · Primary sources · Checklist
Inventory
- ☐ Systems list (HRIS, CRM, IDP, ticketing, SOC)
- ☐ Data fields and retention
- ☐ Overseas recipients and admin roles
- ☐ Vendor sub-processors
Legal mechanism
- ☐ Export vs local-only decision recorded
- ☐ SCC / assessment / certification path chosen
- ☐ Impact assessment completed
- ☐ Filing/approval evidence stored
People & process
- ☐ Employee/customer notices updated
- ☐ Separate consents captured where required
- ☐ China incident response contacts named
- ☐ Annual re-threshold review scheduled
Hub: MNC data hub · SCC detail: SCC timeline.
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