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China’s Amended Cybersecurity Law Takes Effect

By Philip Ruan, Jena M. Valdetero & Andrea C. Maciejewski on February 12, 2026
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Shanghai Skyline
Shanghai, China city skyline on the Huangpu River.

The amended Cybersecurity Law of China (CSL) entered into force on Jan. 1, 2026. These amendments, officially approved by China’s top legislature in October 2025, mark the first major changes to the law since it took effect in 2017. Without altering obligations of cybernetwork operators under CSL, the amendments specify the penalties applicable to breaches of different obligations, expand the government’s power to enforce against extra-territorial activities jeopardizing China’s cybersecurity, and set forth certain policy and regulatory goals for the new governance regime on developing and applying AI.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Photo of Philip Ruan Philip Ruan

Philip Ruan is a member of GT’s Corporate & Securities Practice, focusing on China-related transactions including venture capital, M&A and collaborative deals, with a focus on the life science industry. Philip also advises clients over China-related regulatory matters regarding foreign exchange, data, anti-bribery…

Philip Ruan is a member of GT’s Corporate & Securities Practice, focusing on China-related transactions including venture capital, M&A and collaborative deals, with a focus on the life science industry. Philip also advises clients over China-related regulatory matters regarding foreign exchange, data, anti-bribery, etc.

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Photo of Jena M. Valdetero Jena M. Valdetero

Jena M. Valdetero serves as Co-Chair of the firm’s U.S. Data Privacy and Cybersecurity Practice, and is a trusted advisor to clients facing complex and high-stakes data privacy and security challenges. With a track record of leading thousands of data breach investigations for…

Jena M. Valdetero serves as Co-Chair of the firm’s U.S. Data Privacy and Cybersecurity Practice, and is a trusted advisor to clients facing complex and high-stakes data privacy and security challenges. With a track record of leading thousands of data breach investigations for more than 20 years, Jena combines her broad litigation experience with a deep understanding of the evolving privacy landscape to protect her clients’ interests. She is highly skilled in defending companies in privacy and data breach litigation, particularly class actions, and is proactive in helping clients prepare for incidents by designing and facilitating customized tabletop exercises.

Jena offers practical, results-driven counsel on data privacy and security compliance programs and guides clients through privacy and cyber risk considerations in mergers, acquisitions, venture capital, and securities transactions. Her experience spans a wide range of privacy laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Gramm Leach Bliley Act (GLBA), and the Health Insurance Portability and Accountability Act (HIPAA). Certified as a privacy professional through the International Association of Privacy Professionals (CIPP/US),  Jena provides clients with actionable insights on both current and emerging privacy regulations. She previously served as KnowledgeNet Co-Chair for the International Association of Privacy Professionals, further reflecting her leadership in the field. Jena is a founding board member of the Chicago Compassion Project, a nonprofit supporting low-income families in Chicago.

Jena has been recognized by Chambers USA as a leading privacy and data security lawyer, with clients praising her “very deep knowledge of subject matter” and calling her “extremely responsive and business-minded.” She is trusted for her “great strategic advice” and practical approach to complex data privacy issues, with one client saying, “I’d unequivocally recommend her to anybody with any kind of privacy or data breach concerns.”

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Photo of Andrea C. Maciejewski Andrea C. Maciejewski

Andrea C. Maciejewski designs and implements privacy and security programs for clients of all sizes – from Fortune 500s to start ups – and in all sectors, including digital entertainment, marketing, online education, retail, and consumer goods. Andrea helps companies navigate the intricacies

…

Andrea C. Maciejewski designs and implements privacy and security programs for clients of all sizes – from Fortune 500s to start ups – and in all sectors, including digital entertainment, marketing, online education, retail, and consumer goods. Andrea helps companies navigate the intricacies of multi-jurisdictional compliance programs as well as compliance with sector-specific data privacy and security laws. Andrea offers clients practical legal counsel, striving to understand the underlying business model and provide strategies that manage costs and risks, while attempting to maintain the businesses operations.

Her practice includes international data privacy laws and regulations, including the General Data Protection Regulation (“GDPR”) and China’s Personal Information Protection Law (“PIPL”), as well as U.S. federal and state data privacy laws, such as the Children’s Online Privacy Protection Act (“COPPA”), the Family Educational Rights and Privacy Act (“FERPA”), and the California Consumer Privacy Act (“CCPA”). Some of the specialized documents Andrea drafts include data processing addendums, intracompany agreements, cross-border transfer mechanisms, privacy policies, privacy impact assessments, and data inventories. She has experience in U.S. and multi-national record retention practices, and frequently counsels on updating those practices for compliance with new privacy laws.

Additionally, Andrea provides expert counsel on data concerns unique to video games, eSports, and mobile gaming.

Read more about Andrea C. MaciejewskiEmailAndrea's Linkedin Profile
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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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