Mapping a Hainan entity's cross-border data flows, determining the route each needs, and coordinating the PRC law firm that gives the legal opinion and prepares any filing.
What this covers
- An inventory of the entity's systems, vendors, and integrations, with where each processes and stores data
- A check of each flow against the Free Trade Port data export list and the national thresholds
- A determination of the route each flow needs — none, a standard contract filing, certification, or a security assessment
- The personal-information impact assessment and filing pack prepared with the law firm
- The PRC law firm's opinion on any contested classification, coordinated and kept with the engagement record
- An annual review of the inventory as systems and vendors change
Our services
Classification before complianceThe route depends on the data and the volume, not on foreign ownership.
Whether a data flow triggers an obligation depends on classification — what category the data falls into, what volume applies, and whether the flow is the kind the rules are aimed at. It does not depend on the entity being foreign-owned, and it cannot be answered in the abstract: it depends on what the entity's own systems actually do.
A Hainan list, applied carefullyData outside the Free Trade Port list may move without the national routes — once it has been classified.
Hainan has gone further than the national position on one point. The Free Trade Port's data export list names the data and scenarios that need a formal route, and, as published, data outside the list is not subject to the security assessment, standard-contract filing, or certification the national rules otherwise ask for. That is a real simplification, and it is only available to a flow that has first been classified and found to sit outside the list. The list is administered locally and revised; we confirm current terms for each engagement.
The inventory is operational firstEvery system and vendor, and where each really processes data.
Most gaps are found in vendor relationships — a cloud tool, a support platform, a payroll provider whose servers sit in a jurisdiction nobody mapped. The inventory is operational before it is legal: every system and vendor that touches the entity's data, and where each really processes it.
Legal opinion from a PRC law firmWe coordinate and keep the calendar; the law firm advises.
We build the inventory with the entity's IT, HR, and finance teams, determine the route each flow needs, and coordinate the PRC law firm that gives the legal opinion and prepares any filing. The law firm, not HainanInc, gives legal advice; we keep the engagement on one calendar and keep the inventory current.
Why choose HainanInc?
Every data flow classified before the system depends on it
The route each flow needs determined, not assumed
Inventory reviewed annually as systems and vendors change
Case study
Restoring Good Standing After a Lapsed Registration
A foreign-owned entity's registered address had changed without the corporate register being updated, and a routine regulatory notice went unanswered as a result. By the time the gap surfaced, the entity's standing was in question and a pending contract required proof of good standing within weeks.
Composite illustration based on common engagement patterns; not a specific client.
All Entity Management and Governance services
- Annual Compliance Programme
- Compliance and Governance
- Regulatory Reporting and Entity Health Checks
- Corporate Services
- Beneficial Ownership and Registry Filings
- Legal Representative and Director Duties
- Ownership Changes and Transaction Filings
- Multi-Entity and Family Group Administration
- Cross-Border Data Transfers
- Deregistration and Entity Exit
Our services
Our practice areas cover the whole life of a presence in Hainan — from the market-entry assessment made before anything is filed, through formation, tax incentives, customs and zero-tariff compliance, and annual compliance, to the work permits, outbound investment, and deregistration around it. One engagement model means a single accountable team across all of them.
