(örnek amaçlı olup, gerçekte herhangi bir dergide yayımlanmamıştır.)
Data Privacy Laws: A Comparative Study Between the European GDPR and the US CCPA
By John A. Davies and Emily R. Clark
School of Law, Sample University
Abstract:
This article offers a comparative analysis of the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), aiming to understand the distinctions and similarities in data protection approaches.
Introduction:
With the advent of the digital age, personal data protection has become paramount. Different jurisdictions have approached the issue with varying degrees of stringency. This paper focuses on two significant pieces of legislation: the GDPR and the CCPA.
Legislative Background:
While the GDPR is a comprehensive regulation affecting all European Union member states, the CCPA is state-specific, impacting businesses operating in California.
Key Provisions Comparison:
Data Subject Rights: Both laws grant rights to individuals concerning their personal data. However, GDPR provides a broader set of rights.
Scope and Jurisdiction: The GDPR applies to any entity processing EU residents’ data, whereas the CCPA focuses on larger businesses or those deriving significant portions of their revenue from selling consumer data.
Penalties: GDPR’s fines can reach up to 4% of a company’s global annual turnover, while CCPA’s fines are per violation.
Implications for Businesses:
Companies operating internationally need to be aware of and compliant with both regulations, which can be a challenging endeavor.
Conclusion:
Though there are parallels between the GDPR and the CCPA, crucial differences can have significant implications for businesses. As data privacy concerns continue to evolve, so will the laws that address them.