Open AccessData protection regulation: a comparative law approach
Author(s) -
MarcusAbreu de Magalhaes
Publication year - 2021
Publication title -
international journal of digital law
Language(s) - English
Resource type - Journals
ISSN - 2675-7087
DOI - 10.47975/ijdl.magalhaes.v.2.n.2
Subject(s) - data protection act 1998 , privacy policy , transparency (behavior) , information privacy law , information privacy , general data protection regulation , business , scope (computer science) , ftc fair information practice , privacy law , control (management) , compliance (psychology) , computer security , internet privacy , computer science , social psychology , psychology , programming language , artificial intelligence
This paper aims to present a comparative approach to data protection regulations around the world. Most countries possess data protection laws in some level of detail. In order to compare structures of data control and compliance in dissimilar systems, the study selected four distinct arrangements : the European General Data Protection Regulation (GDPR); the California Consumer Privacy Act (CCPA); the Brazilian Digital Privacy Law, Lei Geral de Proteção de Dados Pessoais (LGPD); and the Chinese Data Privacy Framework, which is molded by a set of different regulations.The analysis was based in common key points of those regulations – territorial scope, consent and disclosure, data security requirements, data transfer, Data Protection Officer, awareness and training, and penalties – to explore the different policies and national goals. The paper argues that, in the landscape of the information based society, new law is needed to protect citizens’ rights to privacy and to bound harvesting and mining of personal information to ensure transparency, control, and compliance of the information economy.