top of page

Cross-Border Data Privacy And Justice: Reconciling National Laws With Global Digital Realities




Charu Singh, IILM, Greater Noida


ABSTRACT


The globalization of digital technologies has transformed personal data into a fluid, borderless resource, challenging the traditional jurisdictional boundaries of national legal systems. While states continue to regulate privacy through territorially grounded frameworks such as the GDPR, CCPA, and India’s DPDP Act, the inherently transnational movement of data generates legal conflicts, regulatory uncertainty, and uneven levels of rights protection. This paper examines the justice gap that arises from this fragmentation, analyzing how divergent national standards shape the governance of cross-border data flows. Through a comparative study of major data protection regimes and an evaluation of judicial interventions— including Google Spain, Schrems I, and Schrems II—the research highlights the growing role of courts in mediating privacy disputes within a global digital ecosystem. The paper also assesses emerging international initiatives by the OECD, Council of Europe, APEC, and the United Nations that aim to establish interoperable principles for global data governance. Despite these efforts, geopolitical tensions, digital sovereignty claims, and power asymmetries between states and technology corporations continue to obstruct meaningful harmonization. The study argues that a just and effective cross-border data regime requires globally interoperable standards, equitable participation for developing countries, and stronger international enforcement mechanisms. It concludes that a rights-based, cooperative approach is essential for reconciling national laws with the realities of global digital interconnectivity.


Keywords: Cross-border data privacy; digital sovereignty; GDPR; global data governance; surveillance; Schrems; right to be forgotten; international cooperation; digital justice; data protection frameworks.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

Submit Manuscript: Click here

Licensing: 

 

All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

Disclaimer:

The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

bottom of page