In the judgment establishing individual privacy as a fundamental constitutional right, the Supreme Court highlighted the need for legislation to uphold individual informational privacy and data protection. Privacy and Internet rights advocates have long called for such a law, and the government has finally started taking steps towards this by appointing a committee to make recommendations. As a nation, India lags among world economic and Internet leaders when it comes to data protection. As the country formulates such a law, it may be instructive to look at what other countries have enacted. In this regard, the United States, China, and the European Union have all taken drastically different directions. The EU’s laws may have a significant impact on Indian companies sooner than any Indian law.
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