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Benchmarking the Indian Digital Personal Data Protection Act 2023 against data protection frameworks in Singapore, the EU, US and Australia

Author

Listed:
  • Chacko, Mathew

    (Founding Partner, Spice Route Legal, India)

  • Mishra, Shambhavi

    (Associate, Spice Route Legal, India)

Abstract

This paper benchmarks the Indian Digital Personal Data Protection Act 2023 in comparison to its global counterparts and identifies ambiguities, defects and issues with the new law that might complicate compliance by global businesses. The paper suggests reforms and approaches based on learnings from best practices under data protection laws in the EU, Singapore, the USA and Australia.

Suggested Citation

  • Chacko, Mathew & Mishra, Shambhavi, 2023. "Benchmarking the Indian Digital Personal Data Protection Act 2023 against data protection frameworks in Singapore, the EU, US and Australia," Journal of Data Protection & Privacy, Henry Stewart Publications, vol. 6(2), pages 110-119, December.
    • Handle: RePEc:aza:jdpp00:y:2023:v:6:i:2:p:110-119
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    More about this item

    Keywords

    Digital Personal Data Protection Act 2023; GDPR; PDPA; APPs; Indian data laws; American Data Privacy and Protection Act;
    All these keywords.

    JEL classification:

    • K2 - Law and Economics - - Regulation and Business Law

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