SANCTITY OF PERSONAL DATA: A COMPARATIVE STUDY OF DATA PRIVACY LAWS IN EU, US AND INDIA
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DOI:
https://doi.org/10.55662/Abstract
With increasing digitization of every sphere of the world, it is imperative to keep data secure. In this study, I intend to do an in-depth analysis of the existing Data Protection Laws in three countries, namely The United States of America, United Kingdom, and India. The paper will be a comparative study of data protection laws in the chosen jurisdictions to bring out their stance against GDPR. The paper discusses the pre and post GDPR scenario of EU followed by the existing legislation of US, in order to compare the approach of the two states. In the last segment, the fragments of Indian legislation to protect data are discussed with a focus on its obligation to become of GDPR complaint nation, if need be. The focus has been laid on Indian laws as the Indian judiciary took massive steps such the decision in the Puttuswamy case granting the Indians citizen, right to privacy as a fundamental right and the recent B.R. Krishnan report on the Data privacy bill, shows the high intention for the same. The purpose of this comparative study is to point out the similarities between the chosen states with an emphasis on India and the paper aims to bring up the point of differences between the countries and serve as a basis of amendments that could be brought in the existing Indian data protection laws.
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