A Comparative Analysis Between GDPR and CCPA: How Regulatory Frameworks Address Privacy and Data Protection

Abstract

This study undertook a comparative qualitative analysis between the European Union’s General Data Protection Regulation (GDPR) and the United States’ California Consumer Privacy Act (CCPA), two pivotal legal frameworks shaping modern data protection and privacy standards. Despite their shared objective of enhancing data privacy, these frameworks face different regulatory challenges. Thus, this study sought to answer the research question: How do these regulatory frameworks address privacy and data protection? The study’s main argument was that while both frameworks aim to protect individual data, their legal approaches and cultural foundations differ. The GDPR offers a more comprehensive and stringent consent model compared to the CCPA, which is more flexible and consumer-centred. To explore this, the study delved into how each regulation addresses enforcement penalties, legal specificity, consent, transparency, accountability, and stakeholder participation. The findings highlight the strengths and weaknesses of each regulation and provide recommendations for stakeholders to improve data protection.