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Subtitle
A Comparative Study of Regulatory Frameworks in the European Union and the United States.
Abstract
Focus on the "Why" and "What."
This research examines the divergent approaches to data privacy between the EU’s General Data Protection Regulation (GDPR) and the sector-specific regulatory environment of the US. By comparing legislative intent, enforcement mechanisms, and the definition of "privacy as a right" versus "privacy as a consumer interest," this study highlights the geopolitical implications of digital governance.
Introduction
- Context: The rise of the "Surveillance Economy" and the necessity of state intervention.
- Problem Statement: While both regions value privacy, their legal philosophies differ fundamentally, leading to international trade friction and varying levels of citizen protection.
- Argument: The EU’s "rights-based" approach creates a global gold standard (The Brussels Effect), whereas the US "market-based" approach prioritizes innovation but results in a fragmented legal landscape.
| State | Population | m/f ratio |
| Odisha | 1000000 | 45% |
| Asam | 200000 | 35% |
Research Ques & Method
Research Questions: 1. How do the legal definitions of "personal data" differ between the EU and the US? 2. To what extent does the GDPR influence American state-level legislation (e.g., California’s CCPA)?
Methodology: This study employs a Qualitative Comparative Analysis (QCA), reviewing primary legal texts, judicial rulings (such as the Schrems II case), and policy reports from 2018 to 2024.
Figure 1
Results & Discussion
| Feature | European Union (GDPR) | United States |
| Philosophical Base | Privacy as a Fundamental Human Right. | Privacy as a Contractual/Consumer Right. |
| Regulation Style | Comprehensive/Omnibus. | Sectoral (HIPAA, GLBA, etc.). |
| Consent | Opt-in (Explicit). | Opt-out (Implicit/Varies). |
| Enforcement | Data Protection Authorities (DPAs). | Federal Trade Commission (FTC) & State AGs. |
References
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