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IAPP CIPP-CN Exam Syllabus Topics:

SectionWeightObjectives
Personal Information Protection Law (PIPL) Core Requirements40-45%- Legal bases for processing
  • 1. Legal obligation, public interest, and legitimate interests
    • 2. Consent and withdrawal of consent
      • 3. Contractual necessity
        - Principles of personal information processing
        • 1. Lawfulness, legitimacy, necessity, and good faith
          • 2. Purpose limitation and data minimization
            • 3. Accuracy and retention limitation
              - Obligations of processors and controllers
              • 1. Transparency and notice requirements
                • 2. Data security measures and breach notification
                  • 3. Data protection impact assessment (DPIA)
                    - Data subject rights
                    • 1. Right to withdraw consent and lodge complaints
                      • 2. Right to data portability and objection
                        • 3. Right to access, correction, deletion, and restriction
                          - Cross-border data transfer rules
                          • 1. Restrictions and exceptions
                            • 2. Standard contractual clauses (SCCs)
                              • 3. Security assessment and certification
                                Sectoral Regulations and Special Rules30-35%- Industry-specific requirements
                                • 1. Telecommunications and internet services
                                  • 2. Human resources and employment
                                    • 3. Financial services and healthcare
                                      - Special categories of personal information
                                      • 1. Children's personal information
                                        • 2. Sensitive personal information
                                          • 3. Publicly disclosed personal information
                                            - Compliance and enforcement
                                            • 1. Remediation and compliance programs
                                              • 2. Supervision and inspection mechanisms
                                                • 3. Penalties and legal liabilities
                                                  Introduction to Personal Information Protection in China20-25%- Overview of core laws
                                                  • 1. Cybersecurity Law (CSL)
                                                    • 2. Data Security Law (DSL)
                                                      • 3. Personal Information Protection Law (PIPL)
                                                        - Statutory and regulatory framework overview
                                                        • 1. Legislative structure and hierarchy
                                                          • 2. Regulatory authorities and roles
                                                            • 3. Key concepts and definitions

                                                              IAPP Certified Information Privacy Professional/China Sample Questions:

                                                              Question #1

                                                              What does the principle of "lawfulness, legitimacy, and necessity" imply in personal data processing?
                                                              Response:

                                                              • A. Individuals must be notified only if their sensitive personal data is used
                                                              • B. Personal data should be processed fairly, within legal boundaries, and only when necessary for a specific purpose
                                                              • C. Data processing should be conducted only after notifying the Ministry of Public Security (MPS)
                                                              • D. Data can be processed for any reason as long as it is properly secured
                                                              Answer: B
                                                              Question #2

                                                              Which of the following entities is required to comply with PIPL, even if its data processing activities are conducted outside China?
                                                              Response:

                                                              • A. A Chinese citizen using an international social media platform
                                                              • B. A Chinese expatriate residing abroad
                                                              • C. A foreign e-commerce website selling products to Chinese consumers
                                                              • D. A foreign company without Chinese customers
                                                              Answer: C
                                                              Question #3

                                                              Which type of data processing is considered under the extra-territorial scope of the PIPL?
                                                              Response:

                                                              • A. Data storage on non-Chinese cloud servers
                                                              • B. Data processing involving Chinese government records abroad
                                                              • C. Processing customer data from Chinese citizens by a foreign e-commerce platform
                                                              • D. Internal company communications outside of China
                                                              Answer: C
                                                              Question #4

                                                              A social media platform in China experiences a major data breach, exposing millions of users' personal data. What legal obligations must the platform fulfill under Chinese data protection laws?
                                                              Response:

                                                              • A. Conduct an internal investigation without public disclosure
                                                              • B. Delete all compromised accounts to minimize media coverage
                                                              • C. Report the breach to the CAC, notify affected users, and strengthen internal data protection measures
                                                              • D. Wait for a legal notice before taking any action
                                                              Answer: C
                                                              Question #5

                                                              Which type of personal data processing would be considered a violation in the employment context under Chinese law?
                                                              Response:

                                                              • A. Using employee work performance data for evaluations
                                                              • B. Sharing personal contact information with third-party vendors without consent
                                                              • C. Conducting background checks with explicit consent
                                                              • D. Informing employees about changes in workplace data policies
                                                              Answer: B

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