"Global Privacy Showdown: GDPR vs. DPDPA vs. US Data Protection Laws"
Nearly five years after a landmark Supreme Court ruling affirming information privacy as a fundamental right in India, the country enacted its Digital Personal Data Protection Act (DPDPA) on August 11, 2023. This Act incorporates principles from global data protection frameworks like the EU and UK GDPR, as well as US laws like California's CCPA. Key principles include informed consent, security measures, and transparency. However, the Act also introduces unique elements, such as a broad definition of "Personal Data" and stringent consent requirements, leaving few alternative lawful bases for processing data. picture credit: https://www.clearycyberwatch.com The DPDPA covers all personal data processing in India and activities related to offering services to Indian residents, extending even to processing outside India. It excludes data processing for personal or domestic purposes and publicly available data. The Act places primary obligations on Data Fiduciaries (akin to da...