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China ERP Data Security and Compliance Self-Assessment

Foreign companies running an ERP in China face several overlapping laws: the Cybersecurity Law, the Data Security Law and the Personal Information Protection Law, plus the classified protection scheme. This ten question self-assessment shows where your ERP setup stands.

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1. Where is your China entity's ERP data hosted?

Include production, backup and test copies.

2. Do you know which ERP data contains personal information?

Employees, customer contacts, supplier contacts, field staff.

3. Is there a legal basis and notice for processing employee and contact data?

4. Do you transfer ERP data to headquarters or group systems outside China?

Includes consolidation feeds, BI exports, support access.

5. Has the ERP system been assessed under the classified protection scheme (MLPS)?

6. How is access to the ERP controlled?

7. Is there a process for remote access by overseas support or consultants?

8. Are important business data categories identified and graded?

For example production, customer and pricing data.

9. Do you have a tested incident response and breach notification plan?

10. Are logs of system and data access retained and reviewed?

How to use the assessment

Answer for the China entity's ERP landscape, including backups, test copies and reporting extracts, since these often sit outside the main hosting arrangement. Have IT and legal answer together. The score is a percentage of the maximum and maps to four bands, each with next steps you can export to PDF for the steering group.

What the questions are based on

The questions follow common themes in Chinese data regulation: where data is stored, what personal information is processed and on what basis, how data leaves China, how systems are graded and protected, and how incidents are handled. They are not a legal opinion. Requirements depend on industry, data volume and the type of data, so use the result to prepare questions for your counsel rather than as a verdict.

Data location and hosting contracts
Personal information inventory and legal basis
Cross-border transfer review
Classified protection grading
Access control, logging and incident response

Reading the result

A low score is most often driven by the absence of an inventory and of reviews, not by missing technology. Companies tend to find that group consolidation feeds, BI extracts and overseas support access were never assessed. These are cheap to fix on paper and painful to find in an audit.

Common mistakes

Treating the ERP as the only place data lives is the biggest one: spreadsheets, email attachments and cloud file shares carry the same data. Another mistake is giving overseas consultants standing access to production. Use time limited, logged sessions and avoid copying production data abroad for testing.

Frequently Asked Questions

Is this a legal compliance check?

No. It is a self-assessment that highlights common gaps. Legal obligations depend on your sector, size and data types, so confirm with qualified counsel in China.

Does my ERP need to be hosted inside China?

Not always as a blanket rule, but certain operators and data categories face localization and transfer requirements, and personal information transfers need a lawful mechanism. Check with counsel for your specific case.

What is MLPS 2.0?

It is the multi-level protection scheme for information systems. Systems are graded by importance and must meet matching security requirements, with filing and periodic assessments for higher levels.

Does using a foreign cloud ERP cause problems in China?

It can, depending on where data is stored and how it moves. Many vendors offer a China region operated through a local partner. Review the contract, hosting location and transfer arrangements.

Where the answer to data location is that data must stay on premises, Netray builds private and on-prem AI that works over ERP data without sending it to an external service. We can discuss how that fits your setup.

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