Comparative Study Of Data Protection Laws: USA Vs. India
- IJLLR Journal
- Feb 8
- 1 min read
Aryan Sharma, BBA LLB, Chandigarh University
ABSTRACT
In this digital age, safeguarding data is of utmost importance to protect privacy and honor. This article assesses and contrasts the data protection laws of both the United States of America and India, noting the variations that stem from the legal and cultural traditions. The U.S. utilizes a fragmented approach allowing for laws on industry specific areas such as HIPAA, COPPA, and CCPA while favoring self-regulation to facilitate enforcement. India, however, has a singular framework in the 2023 DPDP Act, ensuring all sectors are covered and making it applicable beyond its borders. While legislative provisions in the US divide control and enforcement of these agencies through sectoral and multi-agency verticals, India’s DPDP Act consolidates data management government functions to provide sectoral rights such as consent and erasure. These schematic models serve to protect privacy and economic goals, but differ in their regulatory concern, manner in which laws are administered, and the level of control exercised by the government. Knowledge of these methods strengthens the argument of how weak and flexible data protection laws should be in the fast growing digital age.
Keywords: Data Protection Laws, Privacy Rights, Digital Personal Data Protection Act 2023, California Consumer Privacy Act (CCPA), Data Localization
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