APIS Consulting

Governance, Risk & Compliance

GRC and virtual leadership for your China operations.

Most foreign-invested entities in China don't need a full security department, they need the judgement at the top of one. We provide that on a fractional basis: virtual CIO, CISO, DPO and PMO roles that carry the mandate without carrying the headcount.

Roles we cover

Four roles, one accountable partner.

Got an internal team already? We complement it rather than compete with it: providing the expertise, capacity or oversight they don't have in-house, so your team does more with confidence.

Virtual CIO

Technology strategy, roadmap, budget and supplier oversight. We align local IT decisions with business priorities and your group's architecture.

Virtual CISO

Strategy, policy and risk ownership. We set direction, run your security programme and speak for it to your board and to HQ.

Virtual DPO

Data-protection accountability under PIPL and GDPR alike, records of processing, cross-border transfer, data subject requests and regulator liaison.

Virtual PMO

The programme office that keeps remediation, certification and security projects moving, with the reporting cadence your group expects.

Where it fits

Built for the gap between HQ and here.

Group hands you a policy framework; local reality is more complicated. We hold both sides, translating group standards into something enforceable in China, and China's requirements into something HQ can sign off.

  • Policy framework aligned to ISO 27001 and group standards
  • PIPL, DSL and CSL compliance held as an ongoing mandate
  • Risk register maintained, not filed and forgotten
  • Certification and audit readiness kept current
  • A single senior point of contact, in FR, EN or 中文

Frequently asked

What is a virtual CISO (vCISO)?

A virtual CISO gives you senior security leadership on a fractional basis — strategy, governance, risk decisions and board-ready reporting — without the cost of a full-time hire. We act as your CISO for China and APAC.

Can you act as our data protection officer for China?

Yes. Our virtual DPO (vDPO) service covers PIPL obligations, records of processing, data-subject requests and cross-border transfer governance, coordinated with your group DPO in Europe.

How is a GRC mandate structured?

Mandates are scoped to your size and risk and run monthly, quarterly or per-project. You get defined deliverables and a named senior consultant, not an open-ended retainer.

What does a virtual CIO do?

A virtual CIO provides senior technology leadership without a full-time executive hire. The role can cover IT strategy and roadmap, budgets, architecture, suppliers, service performance, project priorities and alignment between the China operation and group IT.

What is the difference between a virtual CIO and a virtual CISO?

The virtual CIO owns the broader technology agenda and how IT enables the business. The virtual CISO focuses on information-security strategy, risk and assurance. We can provide either role or coordinate both under one mandate with clear responsibilities.

Can you work alongside our local IT team and headquarters?

Yes. We can fill a missing leadership role, strengthen an existing local team or coordinate execution between local IT, headquarters and service providers. The governance model and decision rights are agreed at the start.

What happens during the first months of a GRC mandate?

We establish stakeholders and reporting lines, review the current environment, confirm priority risks and obligations, and agree a practical roadmap. The precise first deliverables depend on whether the mandate is CIO, CISO, DPO, PMO or a combination.

Can the mandate cover both China requirements and group policies?

Yes. A core part of the role is translating PIPL, the Data Security Law, the Cybersecurity Law and MLPS requirements into controls and evidence that also align with your group policies and recognised standards.

Bring in the oversight you're missing.

We'll scope a mandate to your size and risk, monthly, quarterly or project-based.

Contact APIS Consulting