Data Protection Regulations: A Comparative Analysis of GDPR and CCPA

Abstract

This paper provides a comparative analysis of two significant data protection regulations: the General Data Protection Regulation (GDPR) of the European Union and the California Consumer Privacy Act (CCPA). With the rise of digital connectivity and increasing concerns about data privacy, both regulations aim to safeguard consumer rights while imposing stringent requirements on businesses. The GDPR, enacted in May 2018, applies to all entities processing personal data of EU citizens, establishing comprehensive rights for individuals, including consent, access, and the right to be forgotten. Conversely, the CCPA, effective from January 2020, focuses on California residents, granting rights such as the ability to opt-out of data sales and request data deletion. This study outlines the similarities and differences between these two frameworks, highlighting their scope, applicability, enforcement mechanisms, and penalties for non-compliance. The findings underscore the challenges businesses face in achieving compliance with both regulations, particularly as they navigate the complexities of jurisdictional differences and emerging technologies. As data protection regulations evolve, this analysis serves as a critical resource for stakeholders aiming to understand the implications of GDPR and CCPA for global data governance.