V K Malavika, LLM (Constitutional Law), School of Law, Christ (Deemed to be University), Bangalore
ABSTRACT
Data and privacy security are crucial given the world's rapid digitization in all areas. The comparative data on data protection and privacy issues in three nations, the United States of America, France, and India, allows to explore and lay an emphasis on India's need to, if necessary, to adopt necessary provisions from the laws of these countries with respect to privacy. The legislations enacted and attempted to put in force with regard to data and privacy protection are covered in the study. The Puttuswamy judgement providing Indian citizens the right to privacy as a basic right and the recent B.R. Krishnan report on the Data privacy bill, which demonstrates the strong intention for the same, are just two examples of the significant measures the Indian judiciary took. The goal of this comparative study is to highlight the commonalities between the selected states, with a focus on India. It also attempts to highlight the disparities between the nations and serve as a foundation for potential changes to the current Indian data protection laws.
