New Guide Compares Privacy Laws in EU and California

Dec 11, 2018


The Future of Privacy Forum and DataGuidance have released a new report, Comparing Privacy Laws: GDPR v. CCPA, which analyzes and contrasts the European Union’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA). GDPR, which became effective in the EU on May 25, 2018, and the CCPA, scheduled to go into effect January 1, 2020, both aim to protect individuals’ personal data and apply to businesses that collect, use or share that data, online or off.

The report details how the two laws differ in significant ways, including their scope of applicability, the extent of collection limitations and rules concerning accountability. However, they are similar in certain definitions, the establishment of additional protections for people under age 16 and the inclusion of rights to access personal information, among other provisions.

The guide compares the two pieces of legislation based on their scope, key definitions, legal basis, the rights they provide, and their approach to enforcement. Each topic includes relevant articles and sections from the two laws, a summary of the comparison, and a detailed analysis of the similarities and differences between the GDPR and the CCPA.

FPF has long supported a comprehensive federal consumer privacy law, believing that both businesses and consumers will gain from one clear standard that provides necessary protections for consumers and certainty and guidance for industry. FPF recommends that such a law address issues of interoperability with existing federal sectoral laws and global privacy frameworks while avoiding conflicts with existing requirements in order to promote beneficial cross-border data flows.


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