Hogan Lovells - Asia-Pacific Data, Privacy and Cybersecurity Guide 2025 - Flipbook - Page 29
Asia-Pacific Data Privacy and Cybersecurity Guide 2025
Audit Scope:
· Audits cover 26 critical areas, including
the legality basis of personal information
processing activities, the processing rules,
joint processing, entrusted processing, the
transfer to other personal information
handlers, cross-border transfer, automated
decision-making processing, the processing
of sensitive personal information, etc.
Under the Audit Measures, personal data
handlers processing the personal information
of over one million individuals must designate
a personal information protection officer
responsible for compliance audits. It is still
unclear whether this is aimed to clarify the
threshold for the requirement to appoint a
personal information protection officer (i.e.,
the DPO) under the PIPL.
Additionally, the Audit Measures echo the
PIPL by proposing an independent oversight
mechanism for personal information handlers
providing significant internet platform
services with large user bases and complex
business types. These handlers must establish
an independent body, mainly consisting
of external members, to oversee personal
information protection compliance audits,
regardless of whether the audit is conducted
internally or by a professional institution.
The Audit Measures mark China’s shift toward
a preventive governance model, balancing
regulatory rigor with operational efficiency. By
integrating independent oversight and granular
accountability, the framework aims to bolster
public trust while supporting sustainable
growth in the digital economy.
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