

Children’s Data Privacy: PRC and U.S. State Law Updates for Colleges and Universities
Following a December 29, 2025 notice published by the Cyberspace Administration of China, institutions that handle personal information of children in China must report on their handling activities by January 31 each year (starting January 31, 2026); Several recently effective U.S. state comprehensive data privacy laws impact whether/how institutions may engage in targeted advertising to minors; The same U.S. state laws also impact whether/how institutions may “sell” minors’

Emma Bahner, XL Law & Consulting
2 days ago6 min read


China Penalizes Dior for PIPL Violation
China’s Ministry of Public Security (“MPS”) penalized Dior Shanghai for breaching personal information protection obligations, following an investigation into a data breach incident. MPS identified the following violations during the investigation: failure to implement a cross-border transfer mechanism; failure to fully inform data subjects about how their personal information would be handled by an overseas recipient; failure to obtain separate consent for cross-border trans

Rose Li, XL Law & Consulting
Dec 15, 20254 min read


China Issues New Requirements for Handling of Sensitive Personal Information
On April 25, 2025, TC260 issued the recommended standard Data Security Technology – Security Requirements for Handling of Sensitive...

Rose Li, XL Law & Consulting
Aug 6, 20255 min read


China Releases Guidelines on Reporting the Appointment of Data Protection Officers
On July 18, 2025, the CAC issued guidance on reporting the appointment of personal information protection officers. Handlers that reached...

Rose Li, XL Law & Consulting
Jul 31, 20254 min read


China Releases Draft Amendment to Cybersecurity Law
On March 28, 2025, the Cyberspace Administration of China released a draft amendment to the Cybersecurity Law(“Draft Amendment”) for...

Rose Li, XL Law & Consulting
Jun 4, 20254 min read


State Privacy Enforcement Officials Argue for Strong State Role in Federal Privacy Law
• In a letter to a congressional Privacy Working Group, officials from California and New Jersey argued against preemptive federal...

Alan Grose, XL Law Consulting
May 19, 20252 min read


China Announces Special Measures to Strengthen PIPL Enforcement in 2025
The CAC and three additional departments jointly announced plans to strengthen PIPL enforcement in 2025 by applying special measures to...

Rose Li, XL Law & Consulting
May 12, 20254 min read


China Releases Final Measures for Compliance Audits on Personal Information Protection
Recently, the CAC released the final Measures for the Administration of Compliance Audits on Personal Information Protection...

Rose Li, XL Law & Consulting
Apr 7, 20254 min read


Legal Considerations for Drafting and Negotiating AI Contracts in Higher Education
AI agreements pose many legal risks, including in the areas of data privacy, intellectual property, liability, and bias. Counsel can...
Anne Wilder and Emma Bahner, XL Law & Consulting
Apr 2, 20256 min read


DOJ Issues National Security Regulation to Limit Transfers of Sensitive Data to Countries of Concern
On January 8, 2025, the DOJ issued a new final rule to prohibit or restrict transfers of bulk sensitive personal data and certain U.S....
Alan Grose and Emma Bahner, XL Law Consulting
Mar 13, 202511 min read


EU-China Cross-Border Data Flow Communication Mechanism
On August 27, the European Union and China launched a new Cross-Border Data Flow Communication Mechanism to address problems regarding...

Alan Grose, XL Law Consulting
Jan 24, 20253 min read


First Cross-Border Data Transfer Decision in China
On August 9, 2024, the Guangzhou Internet Court published an opinion in the first cross-border data transfer case in China. The case ...

Rose Li, XL Law & Consulting
Jan 24, 20254 min read


China Releases Final Regulation on Network Data Security Management
On September 24, China’s State Council released finalized Regulations on Network Data Security Management, which took effect on January...
Alan Grose and Rose Li, XL Law Consulting
Jan 24, 20255 min read


China Further Strengthens Protection of Consumers’ Personal Information
On March 19, 2024, China issued the Regulation on the Implementation of the Law of the PRC on the Protection of Consumer Rights and...

Rose Li, XL Law & Consulting
May 7, 20243 min read


Drafting AI Policies: Considerations for Higher Education Institutions
Generative AI poses both opportunities and risks for organizations. Higher education institutions should strongly consider drafting AI...
Emma Bahner, Xinning Shirley Liu, & Anne Wilder
Mar 21, 20249 min read


CAC Imposes RMB 50 Million Fine on China’s Largest Academic Database
On September 6, 2023, the Cyberspace Administration of China (CAC) imposed a fine of RMB 50 million (approximately $7 million USD) on the...
Emma Bahner, Rose Li, and Anne Wilder
Oct 30, 20233 min read


PIPL Cross-Border Transfer Draft Measures: Potential Relief for U.S. Colleges and Universities
On September 28, 2023, Chinese regulatory authorities published Draft Measures on regulating and facilitating cross-border transfers; the...

Emma Bahner, XL Law & Consulting
Oct 13, 20238 min read


GDPR U.S. Adequacy Decision Adopted: How U.S. Institutions of Higher Education May Benefit
This publication was posted on 7/28/2023 (Updated 10/25/2023).

Emma Bahner, XL Law & Consulting
Jul 28, 20235 min read


MOVEit Data Breach: Implications for Higher Ed Institutions
In late May 2023, cybercriminals gained unauthorized access to the personal information of IHEs’ students, employees, and other community...

Emma Bahner, XL Law & Consulting
Jul 27, 20238 min read


Blockchains, NFT Diplomas, and Data Privacy – Oh My!
By now, nearly everyone has heard of “blockchains” and “NFTs,” and some universities are even using them to issue and validate...

Emma Bahner, XL Law & Consulting
Jun 20, 20236 min read

