Data Protection and Privacy Laws: Comparison Between GDPR and India’s Digital Personal Data Protection Act

Abstract

In the digital age, data is a vital resource, fueling economies and governance alike. However, with growing data dependency, issues of privacy and protection have gained unprecedented significance. The European Union's General Data Protection Regulation (GDPR) is often hailed as the gold standard for data privacy globally. In contrast, India, after years of deliberation, enacted the Digital Personal Data Protection Act (DPDPA), 2023, to secure personal data and ensure privacy in alignment with the landmark Puttaswamy judgment. This paper provides an in-depth comparative analysis of GDPR and DPDPA, exploring similarities and divergences in their scope, consent mechanisms, data subject rights, regulatory structures, cross-border data transfers, and enforcement frameworks. The research critically examines how India’s model reflects indigenous policy priorities and evaluates the adequacy of protections it offers in light of global standards.