After soliciting public comments since last November, the
Chinese Ministry of Public Security (MPS) published the finalized
Guideline for Internet Personal Information Security Protection
(Guideline) on April 10, 2019. The Guideline applies to Personal
Information Holders, defined as entities or individuals that
"control and process personal information" through their
provision of services using the Internet, private networks, or
offline. As China's primary cybersecurity regulator under
China's Cybersecurity Law (CSL), MPS previously issued
regulations specific to network operators' multi-level
protection scheme, as well as procedures for China's Public
Security Bureaus (PSB) to inspect Internet service providers. The
voluntary Guideline sets forth MPS-recommended best practices to
"protect cybersecurity and individuals' legitimate
interests" that will likely inform PSB cybersecurity
inspections. Businesses with interests in China are likely to face
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