We identify your highest China data compliance risks before regulators do — then give you a practical roadmap to close them.
CyberSecure is a boutique advisory built for foreign companies operating in China. We focus on real systems, real data flows, and the operational evidence regulators actually ask for.
China compliance is no longer just a legal question.
CAC, MIIT, and PSB inspections are operational. They ask what data is collected, where it goes, who can access it, and whether business teams can show it in practice — not whether a global policy exists.
Foreign companies often rely on global frameworks, outside legal memos, or informal local practices. The gap between those and what regulators actually expect is where exposure builds quietly until something forces it into the open.
Most reviews stop at the regulation. We start at your operations.
Most reviews deliver
- Legal opinions on the regulations
- Generic cybersecurity frameworks
- Policies written for headquarters
- Annual checklist assessments
CyberSecure delivers
- Real systems, data flows, and HR processes in China
- Operational evidence regulators actually request
- Practical guidance translated for China teams
- A prioritized roadmap your business can execute
Scope covers cross-border data, HR & payroll, China-facing websites and apps, ERP / CRM / HRIS / finance and cloud systems, sensitive personal information, and the operational evidence behind it all.
Two ways to engage CyberSecure.
Most clients begin with the Emergency Review to establish a clear baseline, then add ongoing advisory if they need sustained leadership.
Emergency China Compliance Review
A focused review that identifies your highest China cyber and data compliance risks and delivers a practical roadmap to close them.
- Executive risk summary
- Prioritized findings and risk heatmap
- Cross-border data risk snapshot
- Company-specific remediation roadmap
Fractional China CISO
Bounded advisory support for companies that need China compliance leadership without hiring a full-time specialist. CyberSecure advises, reviews, and prioritizes — client teams remain responsible for implementation.
- Monthly executive guidance
- Audit and regulator support
- Review of new systems, transfers, and business changes
- Practical roadmap support
Common triggers.
If any of these apply, an Emergency Review is the fastest way to know where you stand.
- You do not know what China data leaves the country
- You have no clear China compliance baseline
- HR or payroll data is handled in global systems
- Customer, website, or app data is collected in China
- Your global legal team needs practical evidence
- Policies exist, but execution is unclear
- You are preparing for an audit, regulator inquiry, acquisition, or expansion
- You need fast clarity before committing to a larger compliance project
From uncertainty to a practical action plan.
Rapid Review
We assess your highest-risk systems, data flows, and operational evidence.
Prioritized Findings
You receive a clear view of the highest China compliance risks, ranked by exposure.
Practical Roadmap
You receive a practical roadmap to close them and prepare for deeper remediation.
Built from real China compliance execution.
Practitioner experience across CSL, DSL, PIPL, MLPS, and cross-border data — not regulation-watching from a distance.
A practitioner, not a regulator-watcher.
Dustin Kluttz
Founder · CyberSecure LLC
Dustin has built and led China cybersecurity and data compliance programs across 52 legal entities, supported regulator inspections with zero penalties, and trained more than 1,000 China-based data handlers. He works directly with CIOs, CISOs, General Counsel, and China Country Managers to translate CSL, DSL, PIPL, MLPS, and cross-border data requirements into decisions their teams can act on.
2026 CDI Outstanding CISO Award Recipient
A specialist resource behind your client work.
CyberSecure works alongside law firms, consulting firms, HR and payroll providers, accounting firms, and China market-entry advisors — giving clients practical visibility into China data compliance risk beyond legal interpretation or generic cybersecurity advice.
China cyber and data compliance — executive questions.
Straight answers to the questions CIOs, CISOs, General Counsel, and China Country Managers ask most often.
What is a China data compliance review?
A China data compliance review is a focused assessment of how a foreign company collects, stores, uses, and transfers data inside China, measured against CSL, DSL, PIPL, MLPS, and cross-border data requirements. It evaluates real systems, data flows, HR and payroll processes, websites and apps, and the operational evidence regulators expect to see.
When should a foreign company review its China cross-border data exposure?
Companies should review cross-border data exposure before regulator inspections, audits, M&A activity, ERP or HRIS rollouts, new China entities, or whenever employee, customer, or sensitive personal information is routed through global systems outside China.
What is the difference between legal advice and an operational compliance review?
Legal advice interprets the regulations. An operational compliance review tests whether the company's actual systems, data flows, and business execution match those regulations and whether the evidence regulators ask for exists in practice.
Why do global enterprise systems create China data compliance risk?
Global ERP, CRM, HRIS, finance, and cloud platforms often move China employee, customer, and sensitive personal information outside China by default. Without mapping, classification, and a lawful cross-border transfer basis, this creates exposure under PIPL, DSL, and cross-border data rules.
What does an Emergency China Compliance Review include?
A fixed-scope 10–14 day engagement covering the highest-risk systems and data flows, an executive risk summary, a prioritized findings matrix, a cross-border data risk snapshot, and a practical remediation roadmap your China teams can execute.
What is Fractional China CISO advisory?
Ongoing advisory support that gives foreign companies specialist China cyber and data compliance leadership without hiring a full-time CISO. Includes executive guidance, review of new systems and transfers, audit and regulator support, and roadmap oversight.
How can companies prepare for China data compliance audits or regulator inquiries?
Preparation centers on baseline mapping, a current cross-border data inventory, documented evidence of execution (not just policies), trained China-based data handlers, and a prioritized remediation plan. CyberSecure helps clients reach inspection readiness across CSL, DSL, PIPL, MLPS, and cross-border data.
Not sure where your China compliance risk stands?
Start with a focused review of your highest-risk data flows, systems, and operational gaps. Confidential, fixed scope, 10–14 days.