COMPARING INDIA’S DATA PROTECTION LAWS WITH THE EU AND US IN THE DIGITAL ERA

AUTHOR – SANJAY A. MULIK* & DR. R K GUPTA**

* RESEARCH SCHOLAR, NIILM UNIVERSITY, DEPARTMENT OF NIILM UNIVERSITY, KAITHAL

** RESEARCH GUIDE, NIILM UNIVERSITY, DEPARTMENT OF NIILM UNIVERSITY, KAITHAL

BEST CITATION – SANJAY A. MULIK & DR. R K GUPTA, COMPARING INDIA’S DATA PROTECTION LAWS WITH THE EU AND US IN THE DIGITAL ERA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (11) OF 2025, PG. 711-723, APIS – 3920 – 0001 & ISSN – 2583-2344

ABSTRACT

Globally, technology has developed rapidly in recent decades as the internet has become ubiquitous and has eroded geographic barriers to information flow. We have become increasingly dependent on data as our lives become increasingly connected. Data plays a crucial role in every aspect of our daily lives, from social media to banking to retail. Due to the increased interconnectedness, individuals must have control over their personal information. Various sectors in India are being digitized, and the digital India program has been launched, making it one of the world’s largest economies. In response to growing concerns about personal data protection, the Indian government has introduced a number of laws. In its preamble, this bill’s preamble seeks to explain how individual privacy rights, as well as individual data, are protected in a rapidly technologically developing country such as India. The purpose of this study is to investigate the efficiency and challenge of applying data protection law. This dissertation compares Indian law with that of the European Union and the United States in order to determine the scope of improvements based on data protection principles. Rights of individuals, accountability measures for data processors, and remedies for data breaches include enforcement mechanisms, individual rights, and rights for data processors. This will be a fundamental issue in this digital age, and countries must take major steps towards resolving it. We will try to improve the Indian legal framework to gain a better understanding of the grey areas where it may have complex issues.

Keywords: Digital Data Protection, Privacy, Data protection, European Union, Personal Data;