Centre for Internet & Society


Our note on the comparison of the Personal Data Protection Bill with the General Data Protection Regulation an the California Consumer Protection Act can be downloaded as a PDF here

The European Union’s General Data Protection Regulation (GDPR), replacing the 1995 EU Data Protection Directive came into effect in May 2018. It harmonises the data protection regulations across the European Union. In 2018, California passed the Consumer Protection Act (CCPA), to enhance the privacy protection of residents of California. The CCPA came into effect from January 1, 2020, however, the California Attorney General has not begun enforcing the law as yet. The Attorney General will be allowed to take action six months after the rules are finalised, or on July 1, 2020, whichever is earlier 

In India, the Ministry of Electronics and Information Technology had constituted a Committee of Experts to frame recommendations for a data protection framework in India. The Committee submitted its report and a draft Personal Data Protection Bill in July 2018. On December 11, 2019, the Central Government introduced the Personal Data Protection Bill (PDP Bill) in the Lok Sabha.


While the PDP Bill incorporates several concepts of the CCPA and the GDPR, there are also significant areas of divergence. We have prepared the following charts to compare the PDP Bill with the GDPR and the CCPA on the following points: (i) Jurisdiction and scope (ii) Rights of the Data Principal; (iii) Obligations of the Data Fiduciaries; (iv) Exemptions; (v) Data Protection Authority; and (vi) Breach of Personal Data. It is not a comprehensive list of all requirements under the three regulations.

The charts are based on the comparative charts prepared by the Future of Privacy Forum.

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