Data Privacy Frameworks of India, Europe and USA

India recently saw the advent of its new Data Privacy act after years of discussion and deliberation in the parliament. However, it has been argued to be riddled with several pitfalls and issues, especially in comparison with Data privacy and Data protection frameworks of foreign jurisdictions. To understand and analyse these potential issues one can look at the existing regulations and the regulatory framework of different countries with regard to Data Privacy and understand how the law is made and what are its features. At the same time, one has to also look at the different case laws and the actions taken by the regulatory bodies in the pursuance of these laws to understand it even further. The present research takes a look at both approaches and then consolidates the learnings and key areas where the law stands out and is different. The research also presents a comprehensive view of the potential impact on various stakeholders such as individuals, state and state-sponsored services and even private organisations. The stakeholder analysis of private organisations also delivers a key finding of how organisations with a global presence possess compliance with the new law.