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GB/T 39335-2020 (GB/T39335-2020, GBT 39335-2020, GBT39335-2020) & related versions
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GB/T 39335-2020: PDF in English (GBT 39335-2020)
GB/T 39335-2020
ICS 35.040
L 80
Information security technology - Guidance for
personal information security impact assessment
Issued by: State Administration for Market Regulation;
Standardization Administration of PRC.
Table of Contents
Foreword ... 3 
1 Scope ... 4 
2 Normative references ... 4 
3 Terms and definitions ... 4 
4 Assessment principle ... 5 
4.1 Overview ... 5 
4.2 The value of conducting an assessment ... 5 
4.3 Purpose of assessment report ... 6 
4.4 Subjects responsible for assessment ... 8 
4.5 Basic principles of assessment ... 8 
4.6 Elements to be considered in the assessment implementation ... 9 
5 Implementation process of assessment ... 11 
5.1 Analysis of assessment necessity ... 11 
5.2 Assessment preparation ... 13 
5.3 Data mapping analysis ... 17 
5.4 Identification of risk sources ... 18 
5.5 Analysis of the impact of personal rights ... 23 
5.6 Comprehensive analysis of security risks ... 24 
5.7 Assessment report... 25 
5.8 Risk treatment and continuous improvement ... 25 
5.9 Development of report release strategy ... 26 
Appendix A (Informative) Examples of evaluative compliance and assessment
points ... 27 
Appendix B (Informative) Examples of high-risk personal information
processing activities ... 31 
Appendix C (Informative) Commonly used tools for personal information
security impact assessment ... 34 
Appendix D (Informative) Reference method for personal information security
impact assessment ... 37 
References ... 43 
Information security technology - Guidance for
personal information security impact assessment
1 Scope
This standard provides the basic principles and implementation process, of
personal information security impact assessment.
This standard applies to various organizations, to carry out personal information
security impact assessment on their own. At the same time, it can provide
reference for the supervision, inspection, assessment of personal information
security, by the competent regulatory authorities, third-party assessment
agencies and other organizations.
2 Normative references
The following documents are essential to the application of this document. For
the dated documents, only the versions with the dates indicated are applicable
to this document; for the undated documents, only the latest version (including
all the amendments) is applicable to this standard.
GB/T 20984 Information security technology - Risk assessment specification
for information security
GB/T 25069-2010 Information security technology - Glossary
GB/T 35273-2020 Information security technology - Personal information
security specification
3 Terms and definitions
The terms and definitions as defined in GB/T 25069-2010 and GB/T 35273-
2020, as well as the following terms and definitions, apply to this document.
Personal information
Various information, which is recorded electronically or in other ways, which
can identify a specific natural person alone OR in combination with other
information OR reflect the activities of a specific natural person.
scenarios, the responsible and participating departments and personnel, the
identified risks, the list of adopted and proposed security control measures,
residual risks, etc.
Therefore, the purpose of the personal information security impact assessment
report includes but is not limited to:
a) For the subject of personal information, the assessment report can ensure
that, the subject of personal information understands how their personal
information is processed AND how to protect it; the subject of personal
information is enabled to judge whether there are residual risks, which
have not been dealt with.
b) For organizations, which conduct impact assessments, the purpose of the
assessment report may include:
1) In the planning stage of a product, service or project, it is used to ensure
that, the protection requirements of personal information are fully
considered and realized, in the design of the product or service (for
example, the achievability, feasibility, traceability, etc.) of the security
2) During the operation of products, services or projects, it is used to
determine whether the internal and external factors of the operation
(such as changes in the operation team, Internet security environment,
third-party security control capabilities for information sharing, etc.),
laws and regulations have undergone substantial changes; whether it
is necessary to review and correct the results of the impact assessment;
3) It is used to establish a responsibility system, to supervise whether
security protection measures have been taken, for personal information
processing activities, which have security risks, to improve or eliminate
the identified risks;
4) It is used to enhance the personal information security awareness of
internal employees.
c) For the competent regulatory department, the organization is required to
provide a personal information security impact assessment report; the
organization may be urged to carry out the assessment AND take effective
security control measures. When handling personal information security
related complaints, investigating personal information security incidents,
etc., the competent supervisory authority can understand the relevant
situation, through the impact assessment report, OR use the report as
relevant evidence.
d) For the partners of the organization that conducts the impact assessment,
it is used to understand their role and function in the business scenario as
a whole, as well as their specific personal information protection work and
4.4 Subjects responsible for assessment
The organization designates the responsible department or person responsible
for personal information security impact assessment, who is responsible for the
formulation, implementation, improvement of the personal information security
impact assessment work process, AND is responsible for the quality of the
personal information security impact assessment work results. The responsible
department or person is independent AND is not affected by the assessed party.
Usually, the department, which takes the lead in the implementation of personal
information security impact assessment, is the legal department, the
compliance department, or the information security department.
Responsible departments, within the organization, can choose to carry out
personal information security impact assessments on their own, OR hire
external independent third parties, to undertake specific personal information
security impact assessments, based on the specific capabilities of the
For specific products, services or projects, the person in charge of the
corresponding product, service or project shall ensure the development and
smooth progress of personal information security impact assessment activities,
AND provide corresponding support.
When the organization conducts the personal information security impact
assessment on its own, the competent supervisory authority and the client can
request an independent audit, to verify the rationality and completeness of the
impact assessment activity. At the same time, the organization allows the
competent regulatory authorities to obtain evidence on the impact assessment
process AND related information systems or procedures.
4.5 Basic principles of assessment
The basic principle of personal information security impact assessment is as
shown in Figure 1.
a) Interview: Refers to the process, in which assessors talk to relevant
personnel, to understand, analyze, obtain evidence about the processing
of personal information in the information system, the design and
implementation of protection measures. The interviewees include product
managers, R&D engineers, person in charge of personal information
protection, legal responsible personnel, system architects, security
administrators, operation and maintenance personnel, human resources
personnel, system users.
b) Inspection: Refers to the process, by which the assessor observes,
inspects, analyzes the management system, security policies and
mechanisms, contract agreements, security configuration and design
documents, operation records, etc., in order to understand, analyze or
obtain evidence. The objects of inspection are specifications AND
mechanisms and activities, such as personal information protection
strategy planning and procedures, system design documents and
interface specifications, drill results of emergency planning, incident
response activities, technical manuals and user/administrator guidelines,
operation of the information technology mechanism in the information
system hardware/software, etc.
c) Testing: Refers to the process, in which assessors conduct technical
testing, through manual or automated security testing tools, to obtain
relevant information, AND perform analysis to obtain evidence. The object
of the testing is the security control mechanism, such as access control,
identification and verification, security audit mechanism, transmission link
and storage encryption mechanism, continuous monitoring of important
events, testing of incident response capabilities, drill capabilities of
emergency planning.
4.6.3 Work form of assessment
From the perspective of implementation subjects, personal information security
impact assessment is divided into two forms: self-assessment and inspection
Self-assessment refers to the organization's self-initiated assessment of its
personal information processing behavior. Self-assessment can be carried out
by the post or role, which is designated by the organization, to be responsible
for assessment and auditing; OR it can entrust an external professional
organization to carry out the assessment work.
Inspection assessment refers to the personal information security impact
assessment, which is initiated by the upper-level organization of the
organization. The upper-level organization is an organization, which has a
direct leadership relationship with the organization OR is responsible for
supervision and management. Inspection assessment can also be entrusted to
an external professional organization to carry out.
After determining the assessment scale, selecting the assessment method and
the assessment work form, the specific process of the assessment
implementation can refer to Chapter 5.
5 Implementation process of assessment
5.1 Analysis of assessment necessity
5.1.1 Overview
Personal information security impact assessment can be used for compliance
gap analysis; it can also be used for compliance AND to further enhance its own
security risk management capabilities and security level. Therefore, the
necessity of starting the personal information security impact assessment,
depends on the organization's personal information security goals. The
organization can select the business scenarios, which need to start the
assessment, according to actual needs.
5.1.2 Assessment of compliance gap Overview
When the personal information security goal, which is defined by the
organization, is to comply with the baseline requirements of relevant laws,
regulations or standards, THEN, the main purpose of personal information
security impact assessment is to identify the security control measures, that
have been taken for the specific personal information processing activities to
be assessed, as well as the gap between the specific requirements of the
relevant laws, regulations, standards, such as sharing personal information with
a third party in a certain business scenario, whether it obtains the express
consent of the subject of personal information. Overall compliance analysis
The organization can analyze the gap, BETWEEN all the personal information
processing activities involved in a specific product or service AND the
applicable rules, in accordance with applicable laws, regulations, policies and
standards, which are related to the protection of personal information. The
application scenarios of this assessment method include but are not limited to
the following situations:
a) Annual overall assessment of the product or service;
If necessary, the assessor needs to apply for team support, such as a team
composed of representatives from the technical department, related business
departments, the legal department. The organization's internal personal
information security impact assessment requires long-term support, from the
organization's management.
The management needs to allocate necessary resources for the personal
information security impact assessment team.
5.2.2 Develop an assessment plan
The plan needs to clearly stipulate the work to be done to complete the personal
information security impact assessment report, the division of assessment
tasks, the assessment schedule. In addition, the plan needs to consider the
suspension or cancellation of the scenario to be evaluated. Consider the
following aspects, during specific operations:
a) Personnel, skills, experience, abilities;
b) The time required to perform various tasks;
c) The resources required for each step of the assessment, such as
automated assessment tools.
Note: When the involved scenes are complex and consume a lot of resources, it is
recommended to update and iterate the original plan. For routine assessment activities
or situations involving low complexity of the scene to be evaluated, the original plan
can be used OR this step can be simplified.
If consultations with related parties are involved, the plan needs to specify the
circumstances, under which related parties need to be consulted, who will be
consulted, as well as the specific consultation methods (for example, through
public opinion surveys, seminars, focus groups, public hearings, online
experiences, etc.).
5.2.3 Determine the assessment object and scope
Describe the object and scope of the assessment, from the following three
a) Describe the basic information of the system, including but not limited to:
1) Purpose and type of personal information in processing;
2) A description of the information system, which supports current or future
business processes;
3) Departments or related personnel, who perform information system
management responsibilities, as well as their duties or performance
4) A description of the processing methods and scope of personal
information, as well as the roles that have the right to access personal
information, etc.;
5) If it is expected to entrust a third party to process, OR share or transfer
personal information of the information system with a third party,
description of the identity of the above-mentioned third party and the
status of the third party's access to the information system, etc.
b) Describe system design information, including but not limited to:
1) Overview of functional (or logical) structure;
2) Overview of the physical structure;
3) List and structure of information system databases, tables and fields,
which contain personal information;
4) Schematic diagram of data flow, which is divided by components and
5) A schematic diagram of the data flow of the personal information's life
cycle, such as the collection, storage, use, sharing of personal
6) Description of the time node for notifying the personal information
subject AND the time node and work flow chart for obtaining the
consent of the personal information subject;
7) A list of interfaces, which can transmit personal information to the
8) Security measures, during the processing of personal information.
c) Describe the processing flow and procedure information, including but not
limited to:
1) The identity and user management concept of the information system;
2) Operational concept, including information system or part of its
structure using on-site operation, external hosting, or cloud outsourcing;
3) Support concepts, including listing the scope of third parties that can
access personal information, their personal information access
permissions, the locations where they can access personal information,
corporate acquisitions, mergers and acquisitions, global expansion, etc.
When sorting out the results of data mapping analysis, classify personal
information processing activities, based on the type, sensitivity, collection
scenario, processing method, related parties, which are involved in the personal
information; describe the specific circumstances of each type of personal
information processing activity, to facilitate impact analysis and risk assessment
of follow-up classification.
Note: For data mapping analysis, refer to Table C.1 and Table C.2 in Appendix C.
5.4 Identification of risk sources
Risk source identification is to analyze which threat sources are faced by
personal information processing activities, whether the lack of adequate
security measures leads to the existence of vulnerabilities AND triggers security
incidents. There are many factors, which determine the occurrence of personal
information security incidents. In terms of threat sources, there are internal
threat sources and external threat sources, incidents such as data theft as
caused by malicious personnel, data leakage as accidentally caused by non-
malicious personnel. In terms of vulnerability, there are data damage as caused
by physical environment, data leakage, tampering, loss as caused by technical
factors, as well as abuse as caused by improper management.
The threat identification and vulnerability identification methods, which are
described in GB/T 20984, can be used in the analysis process of personal
information security incidents. In order to further simplify the analysis process
of the possibility of personal information security incidents, the elements related
to the possibility of personal information security incidents are summarized into
the following four aspects:
a) Network environment and technical measures. The factors to focus on,
during the assessment, include but are not limited to:
1) Whether the network environment, where the information system
processing personal information is located, is an internal network or the
Internet; different network environments face different threat sources;
information systems, which are connected to the Internet, face higher
2) The interaction method between the information system, which
processes personal information, and other systems, such as whether
to use network interfaces for data interaction, whether to embed third-
party codes, plug-ins, etc. that can collect personal information.
Generally, the more data interactions, the more comprehensive security
measures to prevent risks, such as information leakage and theft;
3) Whether strict identity authentication, access control and other
measures are implemented, in the process of personal information
4) Whether boundary protection equipment is deployed, at the network
boundary; whether strict boundary protection strategy is configured;
whether data leakage prevention technical measures are implemented;
5) Whether to monitor and record the network operation status; whether
to mark and analyze the status of personal information internally or
when interacting with third parties; whether to discover abnormal traffic
and illegal use in a timely manner;
6) Whether technical measures have been taken, to prevent network
intrusions, such as virus and Trojan horse backdoor attacks, port
scanning, denial of service attacks, etc.;
7) Whether to use encrypted transmission, encrypted storage and other
measures, to provide additional protection for personal sensitive
8) Whether to audit the personal information processing activities, at each
stage of personal information collection, storage, transmission, use,
sharing, etc.; whether to alarm abnormal operation behaviors;
9) Whether a complete network security incident early warning,
emergency response, reporting mechanism has been established;
10) Whether to conduct regular security inspections, assessments,
penetration tests, on the information system; whether to perform patch
updates and security reinforcements, in a timely manner;
11) Whether to strengthen the security management of data storage
media; whether it has the ability to backup and restore data;
12) Other necessary network security technical safeguard measures.
Note 1: If the organization refers to other network security, data security related
national standards, to establish a mature security protection system, it may carry
out analysis and assessment, based on its existing foundation.
b) Personal information processing flow. The factors to focus on, during the
assessment, include but are not limited to:
1) Whether the judgment of personal sensitive information is accurate;
7) Whether it is clear that external service personnel, who may access
personal information, need to comply with personal information security
requirements; whether to supervise them;
8) Whether to sign a binding contract and other documents with a third
party, which stipulates the purpose, method, data retention period,
disposal method if beyond the time limit, after the transfer of personal
information to the third party;
9) Whether to conduct regular inspections and audits of third parties'
handling of personal information, to ensure that they strictly implement
contracts and other agreements;
10) Other necessary measures.
Note 3: If the organization establishes a mature security management system,
with reference to other national standards, which are related to network security
and data security, it can be analyzed and evaluated, based on its existing
d) Business characteristics and scale and security situation. The factors to
focus on, during the assessment, include but are not limited to:
1) The business's dependence on the processing of personal information;
2) The amount, frequency, user scale, user peak value, etc. of business
processing or possible processing of personal information;
3) Whether there have been incidents of personal information leakage,
tampering, damage, loss, etc.;
4) Law enforcement and supervision trends, which are related to personal
information protection;
5) Situations of network attacks or security incidents, in the near future;
6) Security-related warnings, which have been recently received or
publicly released.
After the organization fully understands the corresponding content of the above
dimensions, it can identify the measures taken and the current status, through
investigations and interviews, consulting supporting documents, functional
inspections, technical tests. According to the different dimensions of the
analysis of the impact of personal rights and interests in 5.5, it shall carry out a
comprehensive assessment of the likelihood of the occurrence of a security
incident, from the above four aspects.

Standard ID GB/T 39335-2020 (GB/T39335-2020)
Description (Translated English) Information security technology -- Guidance for personal information security impact assessment
Sector / Industry National Standard (Recommended)
Classification of Chinese Standard L80
Classification of International Standard 35.040
Word Count Estimation 26,256
Date of Issue 2020-11-19
Date of Implementation 2021-06-01
Drafting Organization China Electronics Standardization Institute
Administrative Organization National Information Security Standardization Technical Committee
Regulation (derived from) National Standard Announcement No. 26 of 2020
Proposing organization National Information Security Standardization Technical Committee (SAC/TC 260)
Issuing agency(ies) State Administration for Market Regulation, National Standardization Administration