China’s state secrets law is the source of much angst for lawyers. While the concept of protecting state secrets is straightforward – and common to most countries – the breadth and ambiguity of China’s law, and the inconsistent way it is enforced, create unique data privacy challenges for companies operating in the PRC, especially when they are conducting internal investigations that require data to be transferred out of the country. This article, drawing on interviews with a number of attorneys practicing law on the ground in Asia, details six key considerations related to the state secrets laws for companies formulating sensible investigation strategies in China. For our companion article, see “Understanding the Far-Reaching Impact of Chinese State Secrets Laws on Data Flow” (Jul. 6, 2016).