Introduction
Data protection laws are evolving rapidly across the globe. This article provides a comparative analysis of major data protection frameworks.
European Union: GDPR
- Comprehensive rights for data subjects
- Strict obligations for controllers and processors
- Extraterritorial applicability
- Significant penalties (up to €20 million or 4% of global turnover)
Conclusion
While each framework has its unique features, there is convergence around key principles: individual rights, accountability, and transparency. Multinational organisations must navigate this complex landscape with care.