What Are GDPR and PIPL?

GDPR (General Data Protection Regulation) is the EU’s foundational privacy law, in effect since 2018, establishing strict rules for collecting, processing, and transferring personal data of EU residents.

PIPL (Personal Information Protection Law) is China’s first comprehensive data privacy law, effective from November 2021. It governs how personal information of individuals in China is handled by both domestic and international companies.

Both laws aim to protect individuals’ data rights—but differ in enforcement culture, state involvement, and operational obligations.

Key Similarities and Differences

Similarities:

• Extraterritorial Reach: Both apply beyond their borders—organizations outside the EU or China must comply if processing respective citizens’ data.

• User Rights: Both grant rights to access, correct, delete data, and withdraw consent.

• Legal Bases: GDPR allows multiple legal grounds for processing; PIPL focuses heavily on user consent, especially for sensitive data.

Differences:

• Enforcement and Fines: GDPR fines can reach €20 million or 4% of global turnover. PIPL penalties can go up to 50 million RMB or 5% of revenue in China.

• Government Oversight: PIPL emphasizes state control and cybersecurity, giving authorities broad access and audit powers.

• Data Transfers: GDPR uses adequacy decisions and SCCs; PIPL requires security assessments, certifications, or Chinese government approval for cross-border transfers.

Why It Matters

For global organizations, understanding the nuances between GDPR and PIPL is critical to avoid fines, maintain trust, and build compliant data frameworks across both Europe and China.