ABSTRACT
This paper conducts a comparative analysis of personal data protection legislation across the twelve largest economies by GDP — the United States, China, Japan, Germany, India, the United Kingdom, France, Italy, Canada, South Korea, Russia, and Brazil — together representing over 70% of global GDP and more than 50% of the world’s population.
The study examines the origins, development, and current state of data protection law in each jurisdiction, focusing on key definitions of ‘personal data’, fundamental principles, enforcement mechanisms, supervisory authorities, and penalties for non-compliance. Each national framework is assessed in comparative relation to the General Data Protection Regulation (GDPR), which has emerged as the global benchmark and has demonstrably influenced subsequent legislation in Brazil (LGPD), India (DPDP), and beyond.
The analysis reveals that while no universal definition of personal data exists, all examined jurisdictions share common foundational principles — transparency, purpose limitation, and data subject rights — albeit implemented with significant structural and cultural variation. The most marked divergences appear in enforcement regimes, extraterritorial scope, and the protection of children’s data.
Written in 2023, the paper anticipated what has since become a central challenge in global data governance: the regulation of artificial intelligence. The EU AI Act — then in preliminary draft — is identified as the likely next frontier for data protection law, continuing the pattern of European regulation setting the global standard.
Angelillo, Lorenzo, Protection of Personal Data: A Comparative Analysis of the Top 12 Economies by GDP (May 1, 2023).
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