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Global privacy crosswalk

Compare the obligation—not just the acronym. Scope, role and commencement come first.

PrivacyBuilt Editorial · Reference edition 3 November 2026

Duty / decisionEU GDPRCalifornia CCPA / CPRASingapore PDPAIndia DPDP
Applicability & rolesProcessing in an EU/EEA establishment context, or defined targeting/monitoring of people there. Distinguish controller and processor; exemptions and national rules matter.Covered businesses meeting statutory criteria; service-provider, contractor and third-party roles have separate conditions. CPRA amends CCPA, not a second standalone regime.Organisations handling personal data within PDPA scope, with role-specific duties for data intermediaries; exclusions and exceptions matter.Enacted Act addresses specified digital personal data processing and certain extraterritorial offerings. Data Fiduciary and Data Processor roles; substantive applicability provisions are phased, not universally operative today.
Processing groundsSix Article 6 bases; Article 9 adds conditions for special categories. A contract with a vendor is not itself a lawful basis for every processing purpose.Not a GDPR-style six-basis model. Transparency, purpose limitation, proportionality, relevant consent duties and opt-outs must be assessed for the particular activity.Consent, deemed consent and statutory exceptions, together with purpose, notification and other duties; do not import GDPR legitimate interests as a universal basis.Act sets consent and specified legitimate uses, not GDPR’s six bases. Check commencement of sections 4–7 and rules before treating these as current operational duties.
Individual rightsAccess, correction, erasure, restriction, portability, objection and qualifying automated-decision protections, subject to conditions and exceptions.Know/access, deletion, correction, opt-out of sale/sharing and qualifying limits on sensitive information use; non-discrimination and request-specific rules apply.Access, correction and withdrawal of consent, subject to qualifications. Do not assume an identical GDPR erasure or portability framework; verify operative provisions.Act provides access information, correction/erasure, grievance and nomination rights when corresponding provisions apply. Do not promise currently operative rights from enactment alone.
Rights-response timingWithout undue delay, normally one month from receipt; possible further two months for complexity/number, with notice and reasons within initial month. Validate specific clock treatment.Access, deletion and correction generally 45 calendar days; possible further 45 with notice. Other request types, including opt-out, have different clocks under the regulations.Access and correction: respond as soon as reasonably possible; if unable within 30 days, inform the person in writing when a response can be expected, subject to relevant rules.Do not substitute GDPR deadlines. Validate commencement, applicable Rules and the right concerned before assigning an operational deadline.
Breach notificationAuthority: without undue delay and, where feasible, within 72 hours of awareness unless unlikely risk. Individuals: likely high risk, without undue delay, subject to Article 34 exceptions.California general breach notification duties are in separate statutes, including Civil Code sections 1798.29 and 1798.82, not simply a CCPA 72-hour clock. Validate current text and facts.PDPC: significant harm OR significant scale (500+); as soon as practicable, within three calendar days after notifiable determination. Individuals: significant harm, subject to exceptions. Assessment must be expeditious.The Act and Rules include breach obligations in phased substantive provisions. Do not treat the full regime as commenced or infer a universal GDPR-style clock; verify current notifications and other applicable laws.
Transfers & supplier contractsArticle 28 governs relevant processor contracts. Chapter V routes include adequacy, SCCs or approved BCRs where applicable. Evaluate effective protection and supplementary measures for relevant safeguarded transfers.Qualifying contracts restrict service-provider/contractor use and impose obligations. No general GDPR-equivalent adequacy/SCC regime; other laws and contract commitments may apply.Transfer Limitation Obligation requires comparable protection using legally enforceable obligations or an applicable exception. Contractual and intermediary duties need role-specific assessment.Section 16 enables notified transfer restrictions subject to other laws; do not describe GDPR SCCs as the Act’s universal requirement. Check commencement, notified restrictions and sector rules.
Retention & disposalKeep identifiable data no longer than necessary for purposes, with lawful exceptions. Define evidence-based periods and technical enforcement; there is no universal duration.Disclose retention periods or criteria and limit retention to what is reasonably necessary and proportionate for disclosed purposes, subject to statutory conditions.Cease retention or remove association with individuals when purpose is no longer served and legal/business retention is no longer necessary.Act contains erasure/retention duties and exceptions subject to phased commencement. Prepare purpose-led records, but verify operative duties and sector retention laws.

Official source trail

Not exhaustive. National, sector, employment and other laws can add duties. Similar labels do not mean equivalent legal rights or mechanisms.