Right To Privacy

How India’s data protection Bill compares with EU regulation


From UPSC perspective, the following things are important :

Prelims level: Key terms in PDP Bill

Mains level: Personal Data Protection Bill

The Personal Data Protection Bill is in some aspects very similar with some differences to global standards such as European Union’s General Data Protection Regulation. Here is how:

Must read:

Draft Personal Data Protection Bill, 2021

Major similarities

[1] Consent

  • EU: Users must have informed consent about the way their data is processed so that they can opt in or out.
  • India: Processing of data should be done in a fair and transparent manner, while also ensuring privacy

[2] Breach

  • EU: Supervisory authority must be notified of a breach within 72 hours of the leak so that users can take steps to protect information
  • India: Data Protection Authority must be informed within 72 hours; DPA will decide whether users need to be informed and steps to be taken

[3] Transition period

  • EU: Two-year transition period for provisions of GDPR to be put in place
  • India: 24 months overall; 9 months for registration of data fiduciaries, 6 months for DPA to start

[4] Data fiduciary

  • EU: Data fiduciary is any natural or legal person, public authority, agency or body that determines purpose and means of data processing
  • India: Similar suggestions; additionally, NGOs which also process data to be included as fiduciaries


[1] Anonymous information

  • EU: Principles of data protection do not apply to anonymous information since it is impossible to tell one from another
  • India: Non-personal data must come under the ambit of data protection law such as non-personal data

[2] Punishment

  • EU: No jail terms. Fines up to 20 million euros, or in the case of an undertaking, up to 4 % of their total global turnover of the preceding fiscal year
  • India: Jail term of up to 3 years, fine of Rs 2 lakh or both if de-identified data is re-identified by any person.


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