A Qualitative Analysis of Data Protection Laws: A shield for Personal Data Protection concerning California, European Union, China, and India

Abstract

In the past decades, technological innovation and globalization have created a borderless digital space where digital devices continuously generate enormous amounts of data, referred as “Big Data”. Almost every organisation utilizes this data to predict consumer behaviour, future requirements, and trends legally or illegally. This situation prompted government authorities to establish a framework that defines data privacy boundaries before processing consumers' data.The European Union (EU) announced the General Data Protection Regulation (GDPR) 2018 as a standardized data protection law to address privacy concerns. Subsequently, the California Consumer Privacy Act (CCPA), Personal Information Protection Law (PIPL), and Personal Data Protection Bill (PDPB) were proposed in California, China, and India, respectively. These laws represent significant improvements in consumer data protection.This paper briefly outlines the need for data protection laws and examines the most prominent data protection regulations worldwide, including their key features. It provides a comparative study of privacy protection laws on various parameters of personal data protection. The paper intends to exhibit a typical pattern in all data privacy laws while emphasizing their significant differences. It will provide a deep understanding of ‘rights’ for consumers and personal data protection under the mentioned privacy regulations.