Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021).

Apache-2.0Auto-check passedLegal & Compliance

Install China Pipl

skills CLI
$ npx skills add mukul975/Privacy-Data-Protection-Skills --skill china-pipl -a claude-code

Project install by default; add -g for ~/.claude/skills/.

GitHub CLI
$ gh skill install mukul975/Privacy-Data-Protection-Skills china-pipl --agent claude-code

Project scope by default; add --scope user for a personal install. Needs GitHub CLI 2.90.0 or later (public preview).

Manual copy
$ git clone --depth 1 https://github.com/mukul975/Privacy-Data-Protection-Skills.git skills-src && mkdir -p .claude/skills && cp -r skills-src/skills/privacy/china-pipl .claude/skills/china-pipl && rm -rf skills-src

Use ~/.claude/skills/ instead of .claude/skills for a personal install. The folder must contain SKILL.md.

Claude Code skills documentation · loads skills from .claude/skills/

Facts

Skill name
china-pipl
GitHub stars
301
Token cost
~5k tokens
SKILL.md length
2,382 words
Files
5 (incl. scripts, references, assets)
Skills in repo
280
Repo updated
First seen
Licence
Apache-2.0

At a glance

Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021).

  • Works in 3 steps: CAC Security Assessment (Art. 40; CAC… → Standard Contract for Cross-Border… → Personal Information Protection…
  • Tasks that involve Privacy and GDPR
  • SKILL.md covers Overview, Scope and Extraterritorial…, Lawful Bases for Processing… and Consent Framework, plus 7 more sections
  • Runs Python scripts from its folder

What it does

China Pipl is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021). Covers consent requirements, cross-border transfer mechanisms (CAC security assessment, standard contracts, certification), separate consent triggers, and critical information infrastructure obligations. Keywords: PIPL, China data protection, CAC security assessment, cross-border transfer, separate consent, CIIO.

Its SKILL.md is about 5k tokens, which your agent loads only when the skill is triggered. The skill folder holds 7 other files, including scripts, reference files and assets (for example `assets/template.md`, `references/standards.md` and `references/workflows.md`).

It sits in Legal & Compliance, covering Privacy and GDPR and Security review. The repository describes itself as: 282+ structured privacy & data protection skills for AI agents. GDPR, CCPA, EU AI Act, HIPAA, LGPD, PIPL, DPDP Act. The licence is Apache-2.0.

When your agent uses it

  • Tasks that involve Privacy and GDPR
  • Tasks that involve Security review

Example prompts

  • “Use the china-pipl skill to guide compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021)”
  • “/china-pipl”

Requirements

  • Python 3

Workflow steps

3 steps, taken from the step headings in SKILL.md.

  1. CAC Security Assessment (Art. 40; CAC Measures effective 1 September 2022)
  2. Standard Contract for Cross-Border Transfer (Art. 38(2); CAC Measures effective 1 June 2023)
  3. Personal Information Protection Certification (Art. 38(3); TC260 Specification effective November 2022)

What it can do on your machine

Read from SKILL.md and the folder at commit 9b2ef9e. It shows what the files ask for, not the result of running them.

  • Tool permissions

    Pre-approves nothing: there is no allowed-tools line, so your agent's usual permission prompts apply.

    From allowed-tools in the SKILL.md frontmatter.

  • Runs code

    Ships 1 file in scripts/ (Python), which the agent can run.

    From the folder's file list and the shell code blocks in SKILL.md.

  • Network

    No URLs in SKILL.md.

    From URLs in SKILL.md, links to its own repository left out.

  • Credentials

    Names no API keys, tokens, secrets or passwords.

    From names ending in _API_KEY, _TOKEN, _SECRET, _KEY or _PASSWORD in SKILL.md.

Context cost

China Pipl loads about 5k tokens when it runs, and up to ~9.3k if it reads all its reference files. Until then it costs about 107 tokens; SKILL.md has 2,382 words of instructions outside code blocks.

Always · name and description, kept in context so the agent knows when to use it
~107
When it runs · the whole SKILL.md, loaded when a task matches
~5k
With references · SKILL.md plus every file in references/, read only if the agent opens them
~9.3k

Estimates: characters ÷ 4, the usual rule of thumb; real counts depend on the model's tokenizer. Scripts and assets cost tokens only if the agent reads them.

Safety

Auto-check passed

The automated check found no risky patterns in SKILL.md.

Automated static check — not a guarantee. Review scripts before installing. It scans the text of SKILL.md for risky patterns (piping downloads into a shell, reading credential files, hidden Unicode, destructive commands); the scripts in this folder are not scanned.

SKILL.md

The full file from mukul975/Privacy-Data-Protection-Skills at commit 9b2ef9e, republished under its Apache-2.0 licence (© mukul975). 2,382 words, ~4,977 tokens.

Download SKILL.mdSave it as .claude/skills/china-pipl/SKILL.md (or your agent's skills folder). This skill also uses 4 other files; get the full folder from GitHub.
name
china-pipl
description
Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021). Covers consent requirements, cross-border transfer mechanisms (CAC security assessment, standard contracts, certification), separate consent triggers, and critical information infrastructure obligations. Keywords: PIPL, China data protection, CAC security assessment, cross-border transfer, separate consent, CIIO.
license
Apache-2.0
metadata.author
mukul975
metadata.version
1.0
metadata.domain
privacy
metadata.subdomain
global-privacy-regulations
metadata.tags
pipl, china-data-protection, cac-security-assessment, cross-border-transfer, ciio

China PIPL Compliance

Overview

The Personal Information Protection Law of the People's Republic of China (PIPL, 个人信息保护法) was adopted by the Standing Committee of the National People's Congress on 20 August 2021 and took effect on 1 November 2021. The PIPL is China's first comprehensive national personal information protection law, operating alongside the Cybersecurity Law (CSL, effective 1 June 2017) and the Data Security Law (DSL, effective 1 September 2021) to form China's data governance framework.

The Cyberspace Administration of China (CAC, 国家互联网信息办公室) is the primary regulator, with enforcement authority shared among the Ministry of Public Security, the Ministry of Industry and Information Technology (MIIT), and sector-specific regulators.

Scope and Extraterritorial Application

Territorial Scope (Art. 3)

The PIPL applies to:

  1. Processing of personal information of natural persons within the territory of the PRC (Art. 3(1))
  2. Processing conducted outside the PRC of personal information of natural persons within the PRC where the purpose is:
    • Providing products or services to natural persons within the PRC (Art. 3(2)(i))
    • Analysing or assessing the behaviour of natural persons within the PRC (Art. 3(2)(ii))
    • Other circumstances provided by laws or administrative regulations (Art. 3(2)(iii))
Extraterritorial Compliance (Art. 53)

Overseas personal information processors falling under Art. 3(2) must:

  • Establish a dedicated entity or designate a representative within the PRC to handle personal information protection matters
  • Report the name and contact information of the entity or representative to the relevant CAC department

Zenith Global Enterprises implementation: Zenith has designated its Shanghai office (Zenith Global Logistics (Shanghai) Co., Ltd) as the PRC representative entity, with the local Data Protection Manager serving as the designated contact.

Lawful Bases for Processing (Art. 13)

BasisPIPL ArticleKey Requirements
ConsentArt. 13(1)Voluntary, explicit, informed; specific consent for sensitive PI, cross-border transfers, and public disclosure
Contract necessityArt. 13(2)Necessary to conclude or perform a contract to which the individual is a party, or for HR management per lawfully adopted labour rules
Statutory duty or obligationArt. 13(3)Necessary to fulfil statutory duties or obligations
Public health emergencyArt. 13(4)Necessary to respond to public health emergencies or protect life/property in emergencies
Public interest activitiesArt. 13(5)Processing for news reporting, public opinion supervision, or other public interest activities within a reasonable scope
Processing within reasonable scope of lawfully disclosed PIArt. 13(6)Information already disclosed by the individual or through other lawful means
Other circumstances in laws/administrative regulationsArt. 13(7)Catch-all provision for sector-specific legislation

Key distinction from GDPR: The PIPL does not include a standalone legitimate interest basis. Art. 13(6) (processing lawfully disclosed information) is the closest analogue but far narrower in scope.

RequirementPIPL ProvisionImplementation
VoluntarinessArt. 14Consent must not be obtained through deception, coercion, or inducement; services may not be refused solely for withholding consent unless PI is necessary for the service
InformednessArt. 14Individuals must be fully informed before consenting; information provided per Art. 17
ExplicitnessArt. 14Clear affirmative action required; pre-ticked boxes or bundled consent are non-compliant
WithdrawalArt. 15Individuals have the right to withdraw consent; processors must provide convenient withdrawal mechanisms; withdrawal does not affect prior lawful processing
Separate consentArts. 23, 25, 26, 29, 39Required for specific high-risk processing scenarios (see below)

The PIPL requires separate consent (单独同意, dāndú tóngyì) — consent obtained independently from other consent collection — for the following processing activities:

TriggerArticleContext
Provision of PI to other processorsArt. 23When a processor provides personal information to another processor
Public disclosure of PIArt. 25When a processor publicly discloses personal information
Processing images/personal identification from public surveillanceArt. 26Use of images or personal identification information collected via public places for purposes other than public safety
Processing sensitive personal informationArt. 29All processing of sensitive PI requires separate consent plus disclosure of necessity and impact
Cross-border transfer of PIArt. 39International transfer requires separate consent with specified disclosures

Zenith Global Enterprises implementation:

  • Consent management platform configured with separate consent flows for each trigger scenario
  • Customer onboarding includes distinct consent checkboxes for: (a) primary service processing, (b) data sharing with logistics partners, (c) cross-border transfer to headquarters, (d) credit assessment (sensitive PI)
  • Employee consent flows include separate consent for: (a) employment data cross-border transfer, (b) background check (sensitive PI)

Sensitive Personal Information (Art. 28)

Definition

Sensitive personal information (敏感个人信息) is personal information that, once leaked or illegally used, may easily lead to infringement of the dignity of natural persons or harm to their personal or property safety. It includes:

  • Biometric information
  • Religious beliefs
  • Specific identity information (including ID numbers)
  • Medical and health information
  • Financial account information
  • Location tracking information
  • Personal information of minors under 14 years of age
Processing Requirements (Arts. 28-32)
RequirementDetail
Separate consentArt. 29: Separate consent required; written consent where required by laws/regulations
Necessity justificationArt. 28: Must have a specific purpose and sufficient necessity
Impact assessmentArt. 55: Personal information protection impact assessment (PIPIA) required before processing
NotificationArt. 30: Notify the individual of the necessity and impact on rights; for minors under 14, obtain consent from parent/guardian
Retention minimisationArt. 28: Adopt strict protection measures; minimise retention period
Zenith Global Enterprises Sensitive PI Register
Data TypeClassificationPurposeConsent TypePIPIA Reference
National ID numbers (身份证号)Specific identityCustoms clearance identity verificationSeparate written consentPIPIA-CN-001
Financial account informationFinancialPayment processing for freight chargesSeparate consentPIPIA-CN-002
Employee health certificatesMedical/healthOccupational safety complianceSeparate consentPIPIA-CN-003
GPS tracking of delivery vehiclesLocation trackingReal-time shipment tracking for customersSeparate consent (drivers)PIPIA-CN-004

Cross-Border Transfer Mechanisms (Arts. 38-43)

Three Mandatory Mechanisms

The PIPL provides three primary mechanisms for transferring personal information outside the PRC, applicable based on the processor's scale and nature:

1. CAC Security Assessment (Art. 40; CAC Measures effective 1 September 2022)

When required (mandatory for any of the following):

  • Critical information infrastructure operators (CIIOs) transferring any personal information abroad
  • Processors that process personal information of 1 million or more individuals
  • Processors that have cumulatively transferred personal information of 100,000 or more individuals abroad since 1 January of the preceding year
  • Processors that have cumulatively transferred sensitive personal information of 10,000 or more individuals abroad since 1 January of the preceding year

Process:

  1. Conduct a self-assessment (personal information protection impact assessment)
  2. Submit the application to the CAC through the provincial-level CAC office
  3. CAC completes the assessment within 45 working days (extendable by another 15 working days for complex cases)
  4. Assessment valid for 2 years from the date of the assessment result, renewable upon expiry

Zenith Global Enterprises status: As Zenith processes personal information of over 100,000 customers and employees in China, and has transferred personal information of more than 100,000 individuals abroad cumulatively, the CAC security assessment is the mandatory transfer mechanism.

2. Standard Contract for Cross-Border Transfer (Art. 38(2); CAC Measures effective 1 June 2023)

When applicable (must meet all conditions):

  • The processor is not a CIIO
  • The processor processes personal information of fewer than 1 million individuals
  • Cumulative cross-border transfer of fewer than 100,000 individuals' personal information since 1 January of the preceding year
  • Cumulative cross-border transfer of fewer than 10,000 individuals' sensitive personal information since 1 January of the preceding year

Process:

  1. Conduct a personal information protection impact assessment
  2. Execute the CAC-published standard contract with the overseas recipient
  3. File the executed contract with the provincial-level CAC office within 10 working days of effectiveness

Standard contract key provisions:

  • Purpose, scope, and method of processing by the overseas recipient
  • Overseas recipient's obligations regarding data protection
  • Individual rights protection mechanisms
  • Remedies and liability allocation
  • Termination conditions
3. Personal Information Protection Certification (Art. 38(3); TC260 Specification effective November 2022)

When applicable:

  • Cross-border transfers within a multinational group or between entities subject to the same PI protection policies
  • Processors that meet the standard contract thresholds

Process:

  1. The processor and overseas recipient jointly apply to an accredited certification body
  2. Certification body evaluates compliance with the TC260 Specification for Cross-Border Processing Activities
  3. Certification valid for 3 years with annual supervision audits
  4. Both parties must accept supervision by the certification body and the CAC
CAC Relaxation Measures (March 2024)

The CAC issued the Provisions on Facilitating and Regulating Cross-Border Data Flows (effective 22 March 2024), which introduced exemptions:

ExemptionCondition
Contract/HR necessityCross-border transfer necessary for concluding/performing a contract to which the individual is a party, or for HR management under lawfully adopted labour rules
Small volumeProcessor expects to transfer personal information of fewer than 100,000 individuals (excluding sensitive PI) abroad within one year
Free trade zonesTransfers from designated free trade zones subject to the negative list of that zone

Important: These exemptions do not apply to CIIOs, transfers of important data, or transfers exceeding the specified thresholds.

Show full SKILL.md (917 more words)Show less
Zenith Global Enterprises Cross-Border Transfer Register
Transfer IDFlowDestinationMechanismVolumeAssessment Status
CBT-CN-001Customer logistics data → EU HQGermanyCAC Security Assessment150,000+ individualsApproved (valid until August 2026)
CBT-CN-002Employee HR data → Regional HRSingaporeCAC Security Assessment2,500 employeesApproved (valid until August 2026)
CBT-CN-003Vendor payment data → TreasuryUnited KingdomStandard Contract (filed)800 vendorsFiled with Shanghai CAC
CBT-CN-004Shipment tracking data → API partnersJapanContract necessity exemption50,000 individualsExemption documented

Critical Information Infrastructure (CII)

CIIO Obligations Under PIPL

Critical information infrastructure operators (关键信息基础设施运营者, CIIOs) face additional obligations:

ObligationLegal BasisDetail
Data localisationArt. 40Personal information and important data collected/generated during operations within the PRC must be stored domestically
Security assessment for exportArt. 40Mandatory CAC security assessment for any cross-border transfer (no alternative mechanisms)
Annual security assessmentCSL Art. 38Annual network security assessment and submission of assessment reports
Data security officerDSL Art. 27Designate a data security responsible person
CII Sector Identification

The following sectors are designated as CII under the Critical Information Infrastructure Security Protection Regulations (effective 1 September 2021):

  • Public communications and information services
  • Energy
  • Transportation
  • Water conservancy
  • Finance
  • Public services
  • E-government
  • National defence science and industry
  • Other important network facilities and information systems that may endanger national security, people's livelihood, or the public interest if damaged

Zenith Global Enterprises assessment: As a logistics company, Zenith may be designated as CII under the transportation sector if its systems are determined to endanger national security or the public interest if damaged. Zenith maintains ongoing dialogue with the relevant sector authority (Ministry of Transport) regarding CII designation status.

Personal Information Protection Impact Assessment (PIPIA)

Mandatory PIPIA Triggers (Art. 55)
TriggerDescription
Processing sensitive personal informationAny processing of sensitive PI (Art. 28)
Automated decision-makingUsing personal information for automated decisions (Art. 24)
Entrusted processingEntrusting a third party to process personal information (Art. 21)
Cross-border transferProviding personal information to overseas parties (Art. 38)
Public disclosurePublicly disclosing personal information (Art. 25)
Other high-impact processingProcessing that has a significant impact on individual rights
PIPIA Contents (Art. 56)
ElementDescription
Legality and legitimacyWhether the processing purpose, method, and scope are lawful, legitimate, and necessary
Impact assessmentAssessment of the impact on individual rights and interests and the level of risk
Security measuresWhether the protective measures adopted are lawful, effective, and proportionate to the risk
Risk mitigationIdentification of risks and proposed mitigation measures
PIPIA Retention

The PIPIA report and processing records must be retained for at least 3 years (Art. 56).

Individual Rights (Arts. 44-50)

RightArticleImplementation at Zenith Global Enterprises
Right to know and to decideArt. 44Privacy notice in Simplified Chinese on all collection points
Right to restrict or refuse processingArt. 44Opt-out mechanisms in customer portal; employee objection procedure
Right to access and copyArt. 45Self-service data export from customer account; employee requests through HR
Right to portabilityArt. 45(3)Structured export to designated recipient (per CAC implementation rules when issued)
Right to correction and supplementationArt. 46Self-service correction in customer portal; HR system for employees
Right to deletionArt. 47Automated deletion workflows triggered by: purpose fulfilment, consent withdrawal, service termination, processing violation
Right to explanationArt. 48Individuals may request explanation of PI processing rules; processor must provide timely response
Right regarding automated decision-makingArt. 24Right to request explanation of automated decisions; right to refuse decisions made solely through automated means
Right of deceased persons' relativesArt. 49Close relatives may exercise rights of deceased individuals unless deceased arranged otherwise

Enforcement Framework

Administrative Penalties (Arts. 66-69)
Violation LevelOrganisation PenaltyIndividual Penalty (directly responsible person)
General violationsOrder to rectify; warning; confiscation of unlawful income; suspension or termination of related application; fine up to RMB 1 millionFine of RMB 10,000–100,000
Serious violationsOrder to rectify; confiscation of unlawful income; fine up to RMB 50 million or up to 5% of previous year's revenue; suspension of business; revocation of business licenceFine of RMB 100,000–1,000,000; prohibition from serving as director, supervisor, senior manager, or DPO for a specified period
Enforcement Actions

Didi Global CAC Investigation (2021-2022):

  • CAC launched a cybersecurity review of Didi Chuxing following its NYSE IPO in June 2021
  • Didi was found to have committed 16 violations of the CSL, DSL, and PIPL
  • Final penalty (July 2022): RMB 8.026 billion fine (approximately USD 1.2 billion), plus personal fines of RMB 1 million each on CEO and President
  • Significance: Largest data protection fine in China; demonstrated integration of PIPL, CSL, and DSL enforcement

SAMR/CAC App Compliance Campaigns (2021-2025):

  • Regular enforcement campaigns targeting mobile applications for excessive data collection, bundled consent, and failure to provide deletion mechanisms
  • Thousands of apps removed from app stores or required to remediate
  • Zenith Global Enterprises app compliance: Annual audit by external firm; remediation within 15 days of any finding

Compliance Programme Structure

ComponentDetail
PRC representative entityZenith Global Logistics (Shanghai) Co., Ltd
Data Protection Manager (China)Li Wei, Director of Information Security, Shanghai office
PIPIA programmeMandatory PIPIA for all triggers under Art. 55; retained for minimum 3 years
Cross-border transfer complianceCAC Security Assessment approved for primary data flows; standard contracts filed for lower-volume flows
Consent managementPlatform configured for general and separate consent per Arts. 14, 23, 25, 29, 39
TrainingAnnual PIPL compliance training for all PRC employees; quarterly refreshers for data handling roles
Incident response72-hour notification to CAC for incidents affecting PI security; coordinated with headquarters incident response team

© mukul975, Apache-2.0. Rendered from Markdown: HTML in the file is shown as text, images as links, and headings moved down two levels. Raw file

Files

SKILL.md and 4 other files (scripts, references, assets) in skills/privacy/china-pipl of mukul975/Privacy-Data-Protection-Skills.

  • SKILL.md
  • assets/template.md
  • references/standards.md
  • references/workflows.md
  • scripts/process.py

Open the folder on GitHubat commit 9b2ef9e

Compare with similar skills

China Pipl next to the 5 skills that share the most tags, products or categories with it. Stars are the repository's; “used in” counts other GitHub owners with a copy.

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C15tc15t/c15t1.9k1 repos~1.6kAutomated safety check: PassApache-2.0

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Questions about China Pipl

What does China Pipl do?

Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021). China Pipl is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides compliance with China's Personal Information Protection Law (PIPL, effective 1 November 2021).

When should I use China Pipl?

China Pipl fits situations like: tasks that involve Privacy and GDPR; tasks that involve Security review.

How do I install China Pipl in Claude Code?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill china-pipl -a claude-code`. Or copy the skill folder (skills/privacy/china-pipl in mukul975/Privacy-Data-Protection-Skills) into .claude/skills/china-pipl in your project. Claude Code loads it when a task matches its description.

How do I install China Pipl in Codex?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill china-pipl -a codex`. Or copy the skill folder (skills/privacy/china-pipl in mukul975/Privacy-Data-Protection-Skills) into .agents/skills/china-pipl in your project. Codex loads it when a task matches its description.

Can I use China Pipl in Cursor, Gemini CLI or GitHub Copilot?

Cursor, Gemini CLI, GitHub Copilot and OpenCode also load SKILL.md folders. With the skills CLI, run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill china-pipl -a cursor` (or -a gemini-cli, github-copilot or opencode for the others). To copy it by hand, put the folder in .cursor/skills/china-pipl, .gemini/skills/china-pipl, .github/skills/china-pipl and .opencode/skills/china-pipl in your project.

What does China Pipl need to run?

Going by SKILL.md and its folder, China Pipl needs Python for the scripts in its folder. Our summary lists: Python 3.

Does China Pipl access the network?

SKILL.md contains no URLs. Any network use would come from the scripts or tools the agent runs. This is read from the text; nothing was executed.

Is China Pipl safe to install?

Our automated static check of SKILL.md found no risky patterns, such as piping downloads into a shell, reading credential files or hidden Unicode. It is not a guarantee. The check reads SKILL.md only: the scripts in the folder are not scanned, so read them before running anything.

What licence does China Pipl use?

China Pipl is published under the Apache-2.0 licence (declared in SKILL.md). It allows redistribution, so the full SKILL.md is shown on this page.

How many tokens does China Pipl use?

About 5k tokens (SKILL.md is roughly 20k characters). Agents keep only the skill's name and description in context until a task matches; then they load SKILL.md in full. Its references folder adds about 4.4k tokens, read only when the agent opens those files.

What are the alternatives to China Pipl?

Skills that share tags, products or a category with China Pipl: Data Breach Blast Radius (github/awesome-copilot, 40k stars), Cursor Compliance Audit (jeremylongshore/tons-of-skills-marketplace, 2.8k stars), Juicebox Security Basics (jeremylongshore/tons-of-skills-marketplace, 2.8k stars) and Fondo Security Basics (jeremylongshore/tons-of-skills-marketplace, 2.8k stars). The comparison table on this page puts their stars, adoption, token cost, safety result and licence side by side.

Who maintains China Pipl?

mukul975 (a GitHub user) maintains it in mukul975/Privacy-Data-Protection-Skills, which has 301 GitHub stars. The repository holds 280 skills in this directory. The repository was last updated on March 16, 2026.

Source: mukul975/Privacy-Data-Protection-Skills on GitHub. Facts on this page come from the repository at the commit we read; the author's words are quoted as theirs.