In 2021, the People's Republic of China's legislature
enacted the Personal Information Protection Law (PIPL), presenting
a significant challenge for internal investigations within the
jurisdiction.1 Although PIPL often draws comparisons to
the European Union's General Data Protection Regulation (GDPR),
certain provisions of PIPL are even more rigorous, especially
concerning the transfer of personal data and national security
scrutiny in cross-border internal investigations.
At the outset, a specific complexity arises from the lack of
contemplation regarding internal investigations by the drafters of
PIPL. Not surprisingly, the concept of internal investigations was
not specifically addressed in the law nor in official commentary on
the law. A general exception related to human resources management
was introduced during the final draft of the PIPL.2 This
absence of provision for corporate internal investigations,
compounded by the lack of implementing regulations and
