PPL
Protection of Privacy Law, 5741-1981
61 sections indexed, 11 with our notes. Our index and notes; the law itself is at its source: official text ↗ Our index of this law is not complete yet.
Chapter One Infringement of Privacy
What is infringement of privacy
Publication of a photograph of a deceased person
Definitions
Infringement of privacy: a civil wrong
Infringement of privacy: an offense
De minimis
Chapter Two Protection of Privacy in Databases
Definitions
Chapter Two, Article One Protection of Privacy in Databases: Databases
Registration and use of database
Application for registration
Powers of the Registrar
Privacy protection report
Notice to persons asked for information
Register of databases
Right of inspection of information
Inspection of information not in the possession of the database owner
Amendment of information
Appeal to the court
Confidentiality
Responsibility for information security
Possessor of databases of different owners
Security officer
Chapter Two, Article Two Protection of Privacy in Databases: Direct Mail
Definitions
Direct mail
Indicating the source of information
Deleting information from a database used for direct mail
Application to items of knowledge
Non-application to public bodies
Saving of laws
Chapter Three Defenses
Defenses
Exemption
Burden of proof
Rebuttal of defense arguments
Mitigating circumstances
Chapter Four Disclosure of Information by Public Bodies
Definitions
Application to information
Prohibition on disclosure of information
Limitation on the prohibition
Obligations of a public body
Surplus information
Permitted disclosure is not an infringement of privacy
Regulations on disclosure of information
(repealed)
Chapter Five Miscellaneous
Application to the State
Death of the injured party
Limitation period
Application of provisions of the Defamation Law
Evidence of bad reputation, character or past
Additional orders
Compensation without proof of damage
Liability for publication in a newspaper
Liability of printer and distributor
Penalties for offenses of due diligence
Civil wrong
Material inadmissible as evidence
Amendment of the Torts Ordinance
Amendment of the Criminal Procedure Law
Saving of laws
Implementation and regulations
Fees
Commencement
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Scope and definitions
In PPL
- Section 3Definitions
- Section 7Definitions
- Section 9Application for registration
- Section 17CDefinitions
- Section 17GApplication to items of knowledge
- Section 17HNon-application to public bodies
- Section 19Exemption
- Section 23Definitions
- Section 23AApplication to information
- Section 24Application to the State
- Section 27Application of provisions of the Defamation Law
- Section 37Commencement
Reach abroad across 39 laws
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1 | No express extraterritorial clause; the PPA applies the law where processing has a material impact on Israelis, e.g. targeting the Israeli market or local servers. |
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3 | Applies regardless of location if processing occurs in Brazil, targets goods or services to people in Brazil, or data was collected in Brazil. |
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3 | Covers Egyptians anywhere, non-Egyptians in Egypt, and non-Egyptians abroad where the data concerns Egyptians or residents and the act is also criminal there. |
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3 | Applies to controllers in Ghana, foreign controllers using equipment or processors in Ghana, and processing of information originating in Ghana. |
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3 | Applies inside Indonesia and to acts abroad with legal effect in Indonesia or on Indonesian citizens abroad. |
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3 | Applies to controllers and processors outside Kenya that process personal data of data subjects located in Kenya. |
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3 | Applies to controllers and processors outside Nigeria processing personal data of data subjects in Nigeria. |
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3 | Applies to processing in the Kingdom and to processing outside it of personal data of individuals residing in the Kingdom, by any means. |
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3 | Applies to any circumstances that have an effect in Switzerland, even if initiated abroad; some foreign controllers must appoint a Swiss representative. |
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3 | Applies to controllers and processors outside the UAE that process personal data of data subjects inside the State. |
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3 | Applies to anyone collecting or processing personal data in Uganda, and to anyone outside Uganda handling data relating to Ugandan citizens. |
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3 | Applies to foreign entities in Vietnam and to foreign entities directly processing data of Vietnamese citizens and residents in Vietnam. |
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2 | Applies to organizations abroad with an Australian link, including carrying on business in Australia. |
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2 | Applies to for-profit businesses doing business in California that meet revenue or data-volume thresholds, wherever located, for California residents' data. |
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2 | Applies to commercial activity with a real and substantial connection to Canada, and to interprovincial or international disclosures for consideration. |
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2 | Applies outside China when providing products or services to people in China or analyzing their behavior; foreign handlers need a local representative. |
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2 | Applies to foreign controllers offering goods or services to, or monitoring behavior of, residents of Ecuador; non-residents must appoint an agent in Ecuador. |
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2 | Applies to non-EU controllers offering goods or services to, or monitoring the behavior of, people in the EU. |
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2 | Applies to processing outside India connected with offering goods or services to data principals in India. |
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2 | Applies to foreign businesses handling personal information of people in Japan in connection with supplying goods or services to them. |
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2 | Applies to overseas agencies carrying on business in New Zealand, even without a place of business or commercial purpose. |
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2 | Covers non-established controllers that offer goods or services to, or profile, people in Peru; they must appoint a representative. |
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2 | Applies to processing outside the Philippines of citizens' or residents' data where the entity has a Philippine link (contract, branch, business, data collected there). |
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2 | Applies to enterprises collecting, holding, using or communicating personal information about people in Quebec in the course of business. |
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2 | Applies to organizations whether or not resident or with an office in Singapore, in practice when collecting, using or disclosing data in Singapore. |
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2 | No express territorial clause, but foreign controllers meeting Decree thresholds without a Korean address must designate a domestic agent; PIPC applies the Act to services targeting Koreans. |
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2 | Applies to controllers or processors abroad that offer goods or services to people in Thailand or monitor their behavior in Thailand. |
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2 | The law is silent on territory, but the Board requires foreign controllers processing data of people in Turkey to register in VERBIS through a local representative. |
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2 | Applies to non-UK controllers offering goods or services to, or monitoring behavior of, people in the UK. |
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2 | Applies to non-established controllers offering goods or services to, or analyzing behavior of, people in Uruguay, or using means located there. |
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1 | Applies to processing in Colombia and to foreign controllers or processors when Colombian law applies under international norms or treaties. |
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1 | Applies to controllers or processors incorporated in DIFC, and to processing in DIFC including through stable arrangements, wherever the controller sits. |
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1 | Applies to data users controlling data in or from Hong Kong; no express reach over foreign businesses targeting Hong Kong residents. |
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1 | Applies to persons established in Malaysia, or using equipment in Malaysia other than for transit; foreign users must nominate a local representative. |
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1 | Law applies nationwide; the Regulation also reaches non-established controllers that use means located in Mexico (other than transit). |
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1 | Applies to responsible parties domiciled in South Africa, or not domiciled but using automated or non-automated means in the Republic. |
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1 | Applies to controllers active in Zimbabwe and to controllers not established there that use means located in Zimbabwe. |
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0 | No extraterritorial provision; applies to files and databases, public or private, in Argentina. |
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0 | No extraterritorial provision in the current text. |
Principles
In PPL
We don't score this topic in the comparison. The sections on the left are the place to start.
Lawful basis and consent
In PPL
- Section 1Prohibition on infringement of privacy
Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.
- Section 3Definitions
Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.
- Section 8Registration and use of database
Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.
Lawful basis across 39 laws
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3 | Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent. |
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3 | Processing is unlawful without consent, except listed cases such as public sources, state functions, basic listings, contracts and certain financial operations. No legitimate interests. |
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3 | Consent is the default basis, with limited statutory exceptions. |
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3 | Processing only when a law authorizes it or the holder expressly consents; narrow exceptions for public-source and certain internal data. No legitimate interests. |
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3 | Prior, express and informed authorization is required, with narrow exceptions (public authority requests, public data, medical emergencies, civil registry). No legitimate interests. |
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3 | Explicit consent is the default; other grounds are contract, legal obligation and exercising legal rights. No legitimate interests ground. |
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3 | Consent is the default basis; processing without consent only for listed 'legitimate uses' (s.7). No general legitimate interests ground. |
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3 | Consent is the general rule; non-consent processing only where necessary for contract, legal obligation, vital interests, justice and similar listed grounds. |
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3 | Consent is the default basis; processing without consent only under listed exceptions (law, public sources, legal relationship, emergency, health care, court order). No legitimate interests. |
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3 | Consent is the default basis; exceptions listed in the Law (public entities, public sources, contracts, health, anonymized data). No legitimate interests. |
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3 | Consent is the default basis for use and communication, with listed exceptions. |
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3 | Processing without consent is prohibited except in listed cases (public interest, contract, legal obligation, public data and others); no legitimate interests ground. |
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3 | Prior consent is the default; exceptions cover law, national security, medical purposes, legal obligation and contracts. No legitimate interests ground. |
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3 | Consent is the default basis, with exceptions for public sources, state functions, limited listings, contracts and domestic use. No legitimate interests. |
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3 | Consent is the default basis; the Law adds listed exceptions such as contract performance, legal obligations and protecting legitimate rights. |
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2 | Consent or six other bases (contract/HR, legal duty, emergencies, news, public data, other laws); no legitimate interests. |
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1 | No lawful-basis list; collection must be reasonably necessary, and secondary use needs consent, reasonable expectation or an exception. |
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1 | Ten legal bases including consent, legal obligation, contract, credit protection and legitimate interests. |
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1 | Multiple bases including consent, contract, legal obligation, vital interests and legitimate interests. |
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1 | Eight bases including consent, legal obligation, contract, vital interests, public interest and legitimate interest. |
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1 | Six lawful bases, including consent, contract, legal obligation, vital interests, public task and legitimate interests. |
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1 | Prior consent or listed grounds, including contract, legal obligation, and legitimate interests of the controller or a third party. |
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1 | No lawful-basis list; collection must be lawful, fair and for a purpose directly related to the data user's functions. |
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1 | Consent, contract, legal obligation, vital interests, public interest/authority, and legitimate interests. |
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1 | No list of lawful bases; purpose must be specified and notified, and consent is needed for use beyond purpose and for most third-party provision. |
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1 | Consent or listed necessity grounds, including legitimate interests unless unwarranted given harm to the data subject. |
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1 | No lawful-basis list; collection must be for a lawful purpose connected to the agency's functions and necessary for it. |
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1 | Consent or listed necessity grounds, including legitimate interests unless the data subject would not reasonably expect the processing. |
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1 | Multiple bases: consent, contract, legal obligation, vital interests, public order, public authority and legitimate interests. |
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1 | Consent plus other bases, including legitimate interests (since 2023 amendment) after a documented assessment; not for sensitive data. |
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1 | Consent, deemed consent, or exceptions in the First and Second Schedules, including a legitimate interests exception. |
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1 | Six lawful grounds including consent, contract, legal obligation, and legitimate interests of the responsible party or a third party. |
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1 | Consent, law, public duties, contract, vital interests, legitimate interests that clearly override data subject rights, and urgent public safety. |
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1 | No closed list of bases; processing must follow the principles, and breaches are justified by consent, an overriding private or public interest, or law. |
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1 | Consent or six other bases: research, vital interests, contract, public task, legitimate interests, and legal obligation. |
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1 | Explicit consent is the default, but processing without consent is allowed on listed grounds, including contract, legal obligation and legitimate interests. |
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1 | Six GDPR bases plus a new 'recognised legitimate interests' basis (Annex 1) needing no balancing test, in force 5 Feb 2026. |
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1 | Consent or listed grounds including legal obligation, vital interests, public interest and legitimate interests of the controller or third party. |
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0 | No lawful-basis requirement; notice at collection plus purpose limitation, with opt-out of sale/sharing. |
Sensitive data
In PPL
- Section 3Definitions
'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban.
- Section 17BSecurity officer
'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban.
Sensitive data across 39 laws
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1 | 'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban. |
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3 | Processing sensitive data requires both written explicit consent and a licence from the Personal Data Protection Center. |
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2 | No one can be compelled to provide sensitive data; processing only for general interest authorized by law, or dissociated statistics or science. |
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2 | Sensitive information may be collected only with consent and where reasonably necessary, or under listed exceptions. |
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2 | Sensitive data processed only with specific, highlighted consent or under listed exceptions. |
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2 | Sensitive data cannot be processed unless a law authorizes it, the holder consents, or it is needed to grant health benefits. |
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2 | Sensitive data needs a specific purpose, sufficient necessity, strict safeguards and separate consent. |
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2 | Processing sensitive data is prohibited except with explicit authorization or listed exceptions; no activity may be conditioned on providing it. |
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2 | Special categories may not be processed unless a listed condition, such as explicit consent, applies. |
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2 | Processing sensitive data is prohibited unless a listed exception applies, such as explicit consent. |
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2 | Special categories (health, biometrics, religion, etc.) are prohibited unless explicit consent or another listed exception applies. |
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2 | Special personal data (health, religion, ethnicity, sexual life and others) is prohibited unless consent or a listed exception applies. |
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2 | Special care-required information (race, creed, medical history, criminal record, etc.) needs prior consent to acquire and cannot be shared by opt-out. |
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2 | Sensitive personal data may be processed only on listed grounds; health data only by or under health professionals. |
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2 | Health, political, religious, offence and biometric data need explicit consent or a listed exception. |
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2 | Sensitive data needs express written consent (signature, e-signature or other authentication); databases of sensitive data need a legitimate, specific justification. |
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2 | Sensitive data (genetic, biometric, health, religion, politics, ethnicity, sex life, union membership) needs specific consent or a listed ground. |
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2 | Sensitive data, including biometric, genetic and neural data, requires written consent by signature or equivalent. |
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2 | Processing sensitive and privileged information is prohibited except for listed cases such as specific consent, legal authorization or medical emergencies. |
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2 | Sensitive data needs explicit consent or a listed basis; legitimate interests cannot be used; DPIA and DPO triggers apply. |
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2 | Special personal information is prohibited unless consent or a listed exception applies; the Regulator may authorize processing in the public interest. |
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2 | Sensitive data (beliefs, union, politics, health, sex life, etc.) may be processed only with separate consent or where law requires or permits. |
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2 | Sensitive data (incl. genetic, biometric, social assistance, criminal proceedings) needs express consent if relying on consent; disclosing it to third parties needs justification. |
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2 | Sensitive data (health, beliefs, criminal records, biometrics, genetics, etc.) requires explicit consent unless a listed exception applies. |
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2 | Processing special categories, including appearance, clothing and association membership, is prohibited unless an Art. 6(3) exception applies, such as explicit consent, law or employment obligations. Board-set measures are required. |
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2 | Special personal data (beliefs, politics, sexual life, financial, health) may be processed only under listed exceptions, such as freely given consent. |
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2 | Special categories prohibited unless explicit consent or listed condition applies; many conditions need an appropriate policy document. |
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2 | No one may be compelled to provide sensitive data; processing needs express written consent or legal authorization for general interest. |
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2 | Sensitive data list set by Government (now includes banking, credit, location and behavioral data); extra safeguards and notice required. |
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2 | Sensitive, genetic, biometric and health data require written consent or listed exceptions; some uses need Authority authorization. |
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1 | Sensitive personal information defined; consumers may limit its use to listed necessary purposes, with notice required. |
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1 | No special category; sensitivity drives the form of consent, generally express for sensitive information. |
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1 | 'Specific' data (health, biometric, genetic, criminal, child, financial) defined; mainly triggers DPIA and DPO duties rather than a ban. |
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1 | Sensitive information requires express consent for secondary uses and communication. |
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1 | Sensitive data is defined; no separate prohibition, but large-volume sensitive processing triggers DPO and DPIA duties. |
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0 | No special category of sensitive data. |
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0 | No separate sensitive data category; volume and sensitivity only factor into Significant Data Fiduciary designation. |
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0 | No special category in the Act; Biometric Processing Privacy Code 2025 regulates biometrics. |
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0 | No statutory special category; PDPC treats some data as sensitive when assessing security and penalties. |
People's rights
In PPL
- Section 13Right of inspection of information
Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
- Section 14Amendment of information
Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
- Section 17FDeleting information from a database used for direct mail
Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
Rights across 39 laws
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2 | Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data. |
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3 | Confirmation, access, correction, anonymization/blocking/deletion, portability, consent revocation, objection and review of automated decisions. |
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3 | Know/access, delete, correct, portability, opt-out of sale/sharing, limit sensitive data, and ADMT opt-out and access rights. |
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3 | Know and decide, restrict or refuse, access and copy, portability, correction, deletion, explanation and refusal of solely automated decisions. |
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3 | Withdraw consent, access, rectification, erasure, objection (incl. direct marketing), restriction, portability and automated-decision rights. |
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3 | Information, access, rectification, deletion, objection, portability, suspension of processing, and not to be subject to solely automated decisions. |
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3 | Access, rectification, erasure, restriction, portability, objection and rights on solely automated decisions. |
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3 | Information, correction, access, erasure, withdrawal, objection to automated decisions, restriction/suspension, portability and compensation. |
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3 | Information, access, objection, correction, deletion, restriction, portability, and the right not to be subject to solely automated decisions. |
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3 | Access, copy, rectification, erasure, restriction, portability, objection (absolute for direct marketing) and safeguards against solely automated decisions. |
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3 | Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects). |
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3 | Access, rectification, portability, de-indexing or cessation of dissemination, consent withdrawal, and information on automated decisions. |
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3 | Access, correction, deletion, objection (including direct marketing), protection from solely automated decisions, and restriction in limited cases. |
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3 | Access, portability (transmission), correction, erasure, suspension of processing, and the right to object to or seek explanation of automated decisions. |
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3 | Access, rectification, deletion, restriction/prohibition of processing, objection, data portability, and a right to be heard on automated individual decisions. |
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3 | Access, portability, objection, erasure, restriction and rectification. |
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3 | Information and access, portability, correction and erasure, restriction, objection (incl. direct marketing) and rights against automated decisions. |
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3 | Access, rectification, erasure, restriction, portability, objection, and safeguards on significant automated decisions, plus a right to complain to the controller. |
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2 | Access, rectification, updating and suppression; removal or blocking of marketing data at any time. |
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2 | Information (access), modification, deletion and blocking; opposition to use for advertising, market research or surveys. |
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2 | Know, update and correct data; proof of authorization; information on use; complain to SIC; revoke authorization or request deletion. |
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2 | Know and access data, withdraw consent, correct and erase, restrict processing, object, and be told of breaches. |
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2 | Access, correction and deletion, the right to prevent processing, direct marketing opt-out, and rights against solely automated decisions. |
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2 | Disclosure (access), correction/deletion, cessation of use or erasure, cessation of third-party provision, and disclosure of third-party provision records. |
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2 | Access, correction, withdrawal of consent, prevent damaging processing, stop direct marketing and data portability. |
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2 | ARCO rights: access, rectification, cancellation and opposition, including objection to automated processing with significant effects. No portability right. |
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2 | Right to be informed, access, rectification, erasure or blocking, objection (incl. direct marketing), portability and damages. |
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2 | Rights to be informed, access and copy, correction, restriction and destruction; no portability right. |
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2 | Learn whether data is processed and get information (access), rectification, erasure, notice to third-party recipients, objection to solely automated outcomes, and compensation. |
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2 | Access, correction and deletion, objection to damaging processing, direct marketing opt-out, and rights against solely automated decisions. |
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2 | Access, rectification, updating, inclusion, suppression; challenge automated decisions; removal or blocking of marketing data. |
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2 | Be informed, consent and withdraw, access, correction, deletion, restriction, objection, complaint and lawsuit. |
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2 | Information, access, objection, correction and deletion of false data, and protection from solely automated decisions. |
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1 | Access and correction; no statutory erasure, portability or objection rights (direct marketing opt-out aside). |
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1 | Access, correction, and withdrawal of consent; no statutory deletion, portability or automated-decision rights. |
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1 | Access and correction only. |
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1 | Access to information, correction, completion, updating and erasure, grievance redressal and nomination. No portability, objection or automated-decision rights. |
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1 | Access and correction only. |
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1 | Access and correction; data portability enacted but not yet in force; right to withdraw consent. |
Direct marketing
In PPL
- Section 17FDeleting information from a database used for direct mail
Prior written or electronic opt-in for commercial electronic messages, with a narrow existing-customer exception; the PPL also gives an absolute right to opt out of direct mail.
Marketing across 39 laws
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2 | Prior written or electronic opt-in for commercial electronic messages, with a narrow existing-customer exception; the PPL also gives an absolute right to opt out of direct mail. |
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3 | Any marketing use needs prior, express, informed authorization for that purpose; holders may revoke at any time. |
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3 | Direct marketing requires the data subject's prior written consent, and data subjects may later require it to stop. |
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3 | Consent (incl. 'no objection') required before using or providing personal data for any direct marketing; oral consent confirmed in writing within 14 days. |
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3 | Commercial use, including direct marketing, requires express consent; messages must carry a simple opt-out, and objection is absolute. |
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3 | Consent is required for any direct marketing; objection to direct marketing is absolute. |
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3 | Consent for marketing must be obtained directly; one first contact allowed to seek it, no further contact if refused; opt-outs handled within 10 days. |
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3 | Consent required before sending advertising or using personal data for direct marketing; easy opt-out required; no existing-customer exception confirmed. |
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2 | APP 7 requires opt-out; Spam Act 2003 requires opt-in consent for commercial electronic messages. |
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2 | Automated-decision marketing must offer a non-personalized option or easy refusal; marketing otherwise needs consent. |
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2 | Electronic direct marketing requires prior consent, a clear opt-out and a Center licence; consent records kept three years. |
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2 | Absolute right to object to direct marketing; prior consent required for electronic marketing under the ePrivacy Directive, with a customer soft opt-in. |
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2 | Marketing email requires prior opt-in consent under the Act on Regulation of Transmission of Specified Electronic Mail. |
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2 | Commercial electronic messages require consent under the Unsolicited Electronic Messages Act 2007. |
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2 | Electronic direct marketing requires prior opt-in consent, which may be requested only once; existing customers may receive similar offers with an opt-out. |
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2 | Electronic advertising requires the recipient's prior explicit opt-in consent. |
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2 | Opt-in for automated mass advertising (email, SMS), except to existing customers for similar products with an opt-out offered. |
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2 | Commercial electronic messages need prior opt-in consent recorded in the national IYS system; opt-outs must be honored within 3 business days. |
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2 | Prior consent needed for electronic marketing, with soft opt-in for existing customers (extended to charities by DUAA); absolute right to object. |
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2 | Consent required for behavioral and targeted advertising, with an opt-out mechanism, plus anti-spam rules. |
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1 | Marketing may use data from public sources or provided by the holder; holders may demand removal or blocking at any time (opt-out). |
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1 | No specific marketing rule; requires a legal basis, and data subjects may object or revoke consent. |
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1 | Right to opt out of selling or sharing data for cross-context behavioral advertising; email marketing governed by federal CAN-SPAM. |
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1 | Opt-out consent can suffice for non-sensitive secondary marketing uses; commercial electronic messages need opt-in under CASL. |
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1 | Holders may object to use of their data for advertising, market research or opinion surveys (opt-out). |
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1 | Inform subjects before first disclosure for marketing and honor the right to object at any time, offered by the first communication. |
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1 | Data subjects may object at any time to direct marketing, including related profiling. |
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1 | Data subjects may require a controller, by written notice, to stop or not begin processing for direct marketing. |
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1 | Marketing is a secondary purpose disclosed in the privacy notice; data subjects can object or opt out. |
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1 | Data subjects have a right to object to direct marketing; processing must stop on objection. |
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1 | Prospection must identify the enterprise and inform individuals of their right to withdraw consent; electronic messages need CASL opt-in. |
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1 | Check the Do Not Call Register before marketing calls or texts unless clear consent; marketing use of data also needs consent. |
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1 | Data subjects may object to direct marketing at any time; no PDPA-specific opt-in for electronic marketing. |
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1 | Data subjects may object to processing for direct marketing, including related profiling. |
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1 | Data subjects may require a controller to stop direct marketing processing; the controller must respond within 14 days. |
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1 | Marketing profiles only from public sources, data provided by the holder or with consent; holder may request removal or blocking at any time. |
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1 | Data subjects may object free of charge to processing for direct marketing; no opt-in rule. |
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0 | No specific direct marketing rule; marketing requires consent like other processing; targeted ads to children banned. |
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0 | Not addressed specifically; marketing needs a lawful basis and consent can be withdrawn. |
Privacy officer
In PPL
- Section 17BSecurity officer
Required for public bodies, data brokers and direct mailers above 10,000 people, and entities whose core activity is systematic monitoring or large-scale special-sensitivity data.
DPO required across 39 laws
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1 | Required for public bodies, data brokers and direct mailers above 10,000 people, and entities whose core activity is systematic monitoring or large-scale special-sensitivity data. |
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3 | Every organization must designate an individual accountable for compliance. |
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3 | Every controller and processor must designate a person or area to assume the data protection function and handle requests. |
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3 | Every legal-entity controller and processor must appoint a qualified employee as DPO and register them with the Center. |
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3 | Every controller must designate a person or data protection department to handle ARCO requests and promote data protection internally. |
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3 | Every agency must appoint one or more privacy officers. |
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3 | Every personal information controller and processor must designate a DPO or accountable individual, and register one DPO. |
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3 | The person with highest authority in every enterprise is by default the person in charge of personal information protection; may delegate in writing. |
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3 | Every organization must designate one or more individuals responsible for PDPA compliance and publish business contact information. |
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3 | Every public and private body has an Information Officer (the head by default), who must be registered with the Regulator before taking up duties. |
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3 | Every controller must designate a chief privacy officer; small businesses default to the owner or representative. |
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3 | The head of every institution covered by the Act must designate a data protection officer. |
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3 | Every data controller must appoint a DPO and notify POTRAZ on Form DP2. |
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2 | Controllers must appoint an encarregado; ANPD may exempt small processing agents. |
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2 | Statute lets controllers appoint a certified data protection supervisor; DPC guidance requires medium and large controllers to appoint one. |
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2 | Data controllers and processors of major importance must designate a DPO; low thresholds (over 200 data subjects in six months) capture many firms. |
| |
2 | Must appoint qualified data protection personnel or department, or hire a service provider. |
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1 | Not required for organizations; Australian Government agencies must appoint a privacy officer under the Agencies Code. |
| |
1 | Handlers processing personal information above the volume set by the CAC must appoint a personal information protection officer. |
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1 | DPO required for DIFC Bodies and for controllers or processors performing high-risk processing on a systematic or regular basis. |
| |
1 | DPO required for public-sector processing, large-scale systematic monitoring and large-scale processing of special categories. |
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1 | DPO required for public bodies, large-scale systematic monitoring, or large-scale special-category or criminal data processing. |
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1 | Only Significant Data Fiduciaries notified by the government must appoint a DPO; others publish contact of a DPO or responsible person. |
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1 | DPO required for public-service processing, large-scale systematic monitoring, or large-scale specific/criminal data; any one trigger suffices. |
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1 | Controllers and processors may appoint a DPO for public or private bodies, systematic monitoring, or sensitive data processing. |
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1 | Controllers and processors must appoint a DPO when processing data of over 20,000 subjects, sensitive data of over 10,000, or systematic monitoring. |
| |
1 | Data protection officer required for public entities, large-scale or sensitive processing, and core sensitive-data activities; phased in by company size through Nov 2028. |
| |
1 | DPO required for public entities processing at large scale, and where core activities involve systematic monitoring or sensitive data. |
| |
1 | Optional for private controllers; federal bodies must appoint a data protection advisor. |
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1 | DPO required for public authorities, large-scale regular monitoring, or core activities involving sensitive data. |
| |
1 | DPO required for high-risk processing, systematic assessment of sensitive data including profiling, or large-volume sensitive data. |
| |
1 | DPO required for public authorities, large-scale systematic monitoring, or large-scale special-category or criminal data processing. |
| |
1 | DPO required for public bodies, majority state-owned entities, private entities whose core business is sensitive data, and those processing data of over 35,000 people. |
| |
0 | No DPO requirement; executive accountable for risk-assessment attestations and cybersecurity audit certification. |
| |
0 | No DPO requirement. |
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0 | No DPO requirement; controllers must take necessary security control measures, including organizational measures. |
| |
0 | No DPO requirement; registered controllers must appoint a contact person for the Authority and data subjects. |
| |
– | Not addressed |
| |
– | Not addressed |
Registration and licensing
In PPL
Registration across 39 laws
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1 | Registration only for public-body databases and databases of 10,000+ people mainly used to transfer data for payment; notify the PPA of special-sensitivity databases above 100,000 people. |
| |
3 | Controllers and processors need Center licences with fees capped at EGP 2 million, plus permits for transfers, marketing and CCTV. |
| |
3 | Every data controller must register with the Commission, pay a fee and renew every two years; processing unregistered is an offense. |
| |
3 | Controllers and processors must register, pay tiered fees (KES 4,000-40,000) and renew every 24 months; small entities exempt unless in listed sectors. |
| |
3 | All collectors, processors and controllers must register with the PDPO, renew annually and pay fees (UGX 100,000 reported). |
| |
3 | Controllers processing data of 50 or more people need a POTRAZ licence, tiered USD 50-2,500, renewed every 12 months. |
| |
2 | Public databases and private databases that go beyond exclusively personal use must register with the AAIP registry. |
| |
2 | Controllers and processors must register by filing a notification of processing with the Commissioner, kept up to date, with fees. |
| |
2 | Controllers must register with and keep updated the National Personal Data Protection Registry. |
| |
2 | Prescribed classes of controllers (banking, insurance, health, telecoms, education, real estate and others) must register and renew certificates with fees. |
| |
2 | Controllers and processors of major importance must register, with fees of N10,000-250,000 by tier; ordinary-tier entities renew annually. |
| |
2 | Creation, modification and cancellation of personal data banks must be registered (free, automatic approval) with the National Registry. |
| |
2 | Register processing systems and DPO if 250+ employees, sensitive data of 1,000+ individuals, or risky processing; renew annually. |
| |
2 | Controllers must register in VERBIS before processing, unless exempt (under 50 employees and under TRY 100m balance sheet, or under 10 and TRY 10m if mainly sensitive data). |
| |
2 | Most controllers must pay an annual data protection fee to the ICO unless exempt. |
| |
2 | All public and private databases, other than purely personal ones, must be registered with the URCDP, including foreign controllers in scope. |
| |
1 | No general registration; data brokers must register annually with the CPPA under the Delete Act. |
| |
1 | Companies and non-profits above an asset threshold (and public entities) must register databases in the SIC's National Database Registry (RNBD) and update annually. |
| |
1 | No PDP Law registration; electronic system operators register with the ministry under GR 71/2019. |
| |
1 | No general registration; businesses using the opt-out route for third-party provision must notify the PPC in advance. |
| |
1 | National Register of Controllers applies to public entities, controllers whose main activity is processing, sensitive-data processors and some individuals; no fees seen. |
| |
1 | No general controller registration. Information Officers must be registered; prior authorization needed for listed processing such as credit reporting. |
| |
1 | Public institutions must register personal information files with the PIPC; no registration for private controllers. |
| |
1 | No registration for private controllers; federal bodies must report their processing activities to the FDPIC. |
| |
1 | No controller registration; impact assessment dossiers are filed with the Ministry of Public Security instead. |
| |
0 | No registration of organizations. |
| |
0 | No registration for private controllers; the Civil Registry keeps a registry of public bodies' databases. |
| |
0 | No general controller registration; foreign handlers report their China representative to regulators. |
| |
0 | No general registration; controllers communicate DPO contact details to the supervisory authority. |
| |
0 | Data user return scheme exists but has not been activated for any class of data user. |
| |
0 | No general controller registration. Only Consent Managers must register with the Data Protection Board. |
| |
0 | No registration or notification of databases with the regulator. |
| |
0 | No registration. |
| |
0 | No controller registration. |
| |
0 | No registration of controllers. |
| |
0 | No controller registration or licensing. |
| |
– | Not addressed |
| |
– | Not addressed |
| |
– | Not addressed |
Security
In PPL
We don't score this topic in the comparison. The sections on the left are the place to start.
Regulator
We don't score this topic in the comparison. The sections on the left are the place to start.
Complaints and enforcement
In PPL
- Section 4Infringement of privacy: a civil wrong
Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available.
- Section 13Right of inspection of information
- Section 13AInspection of information not in the possession of the database owner
- Section 15Appeal to the court
- Section 29Additional orders
- Section 29ACompensation without proof of damage
Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available.
Private action across 39 laws
| |
3 | Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available. |
| |
3 | Controllers and processors must compensate material or moral damage; individual and collective actions allowed. |
| |
3 | Private right of action for data breaches from failure to maintain reasonable security: USD 107-799 per consumer per incident, class actions allowed. |
| |
3 | Tort claims with presumed fault of the handler; prosecutors and designated organizations may bring public interest suits. |
| |
3 | Right to compensation for material or non-material damage; representative bodies may bring claims, including collective redress. |
| |
3 | Courts must award punitive damages of at least CAD 1,000 for intentional or grossly negligent infringements; class actions available. |
| |
3 | Damages with reversed burden of proof, up to 5x for intentional or negligent leaks, statutory damages up to KRW 3 million, and group suits. |
| |
3 | Strict liability for damages, plus punitive damages up to twice actual damages; class actions available under civil procedure. |
| |
2 | Habeas data court action to access, rectify, suppress or keep data confidential; liability for damages also arises. |
| |
2 | Statutory tort for serious invasions of privacy (from 10 Jun 2025); representative complaints to OAIC. |
| |
2 | Controller must compensate material and moral damage from improper processing; amount set by the judge. |
| |
2 | Data subjects complain to SIC after exhausting the controller process; damages are claimed under general civil liability. |
| |
2 | Data subjects may sue directly in DIFC Courts for financial and non-financial harm, including distress. |
| |
2 | Data subjects may sue for damages (Constitution art. 92 habeas data) and must be guaranteed full reparation. |
| |
2 | Victims keep the right to claim compensation; entities are jointly liable for employees' violations. |
| |
2 | Individuals who suffer damage or distress from a contravention are entitled to compensation, subject to a reasonable care defense. |
| |
2 | Individuals suffering damage, including injury to feelings, may claim compensation; PCPD may give legal assistance. |
| |
2 | Data subjects may sue for compensation for violations of processing. |
| |
2 | Individuals may sue to compel disclosure, correction or cessation, and claim tort damages under the Civil Code. |
| |
2 | Persons who suffer damage, including distress, are entitled to compensation from the controller or processor. |
| |
2 | Administrative sanctions apply without prejudice to civil liability, so data subjects can claim damages in the civil courts. |
| |
2 | After a Commissioner complaint, individuals may bring proceedings in the Human Rights Review Tribunal for damages. |
| |
2 | Data subjects who suffer injury, loss or harm may sue for damages; the Commission can also order compensation. |
| |
2 | Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action. |
| |
2 | Data subjects may be indemnified for damages from inaccurate or unlawful processing. |
| |
2 | Anyone harmed may seek proportionate compensation for material or moral damage before the competent court. |
| |
2 | Persons suffering loss or damage may sue for injunction, declaration, damages or other relief. |
| |
2 | Data subjects, or the Regulator on their behalf, may sue for patrimonial, non-patrimonial and aggravated damages, regardless of intent or negligence. |
| |
2 | Data subjects can sue for injunctions, rectification or deletion, damages, moral damages and surrender of profits. |
| |
2 | Data subjects can claim compensation in civil courts for damage from unlawful processing; complaints to the Board come after a request to the controller. |
| |
2 | A data subject who suffers damage or distress may apply to court for compensation; complaints also go to the PDPO. |
| |
2 | Individuals can claim compensation for material or non-material damage; representative actions are limited in practice. |
| |
2 | Habeas data court action with summary procedure to access, rectify, include or delete data. |
| |
2 | Violators must compensate damage; controllers and processors liable for losses caused by their processing. |
| |
1 | After a Commissioner complaint, individuals may apply to the Federal Court for damages, including for humiliation. |
| |
1 | Civil courts barred; data principals complain to the Data Protection Board after exhausting grievance redressal. No compensation provision. |
| |
1 | Data subjects may complain to the Data Office; no compensation or civil claim provision. |
| |
1 | No statutory compensation right; data subjects complain to POTRAZ, with appeal to the Administrative Court. |
| |
0 | No statutory right for data subjects to sue for compensation; complaints go to the Commissioner. |
Offenses and penalties
In PPL
- Section 5Infringement of privacy: an offense
Privacy infringement and breach of confidentiality carry up to 5 years in prison; Amendment 13 added offenses such as obstructing or misleading the PPA (6 months to 3 years).
- Section 16Confidentiality
Privacy infringement and breach of confidentiality carry up to 5 years in prison; Amendment 13 added offenses such as obstructing or misleading the PPA (6 months to 3 years).
- Section 31APenalties for offenses of due diligence
- Section 34Amendment of the Criminal Procedure Law
Maximum fine across 39 laws
| |
3 | Tiered administrative fines, many per data subject (e.g., ILS 4-8 per person for sensitive databases), plus fixed amounts up to ILS 640,000 per violation; no overall cap stated. |
| |
3 | Body corporate: greater of AUD 50 million, 3x the benefit, or 30% of adjusted turnover for serious interferences. |
| |
3 | Simple fine up to 2% of Brazil revenue for the prior year, capped at BRL 50 million per infraction; daily fines also possible. |
| |
3 | Up to RMB 50 million or 5% of prior-year revenue; responsible individuals RMB 100,000 to 1 million. |
| |
3 | Serious infringements: 0.7% to 1% of prior-year business volume; public servants 10 to 20 basic salaries. |
| |
3 | Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher. |
| |
3 | Up to INR 250 crore (about USD 30m) per instance for security safeguard failures. |
| |
3 | Administrative fines up to 2% of annual revenue; criminal corporate fines up to 10x individual maximum. |
| |
3 | Greater of N10 million or 2% of prior-year annual gross revenue for entities of major importance; N2 million or 2% for others. |
| |
3 | Penal fines up to CAD 25 million or 4% of worldwide turnover; administrative penalties up to CAD 10 million or 2%. |
| |
3 | Up to 10% of annual Singapore turnover if over SGD 10 million, otherwise SGD 1 million. |
| |
3 | Penalty surcharge up to 3% of total revenue (excluding unrelated revenue); up to 10% for repeat, mass (10m+) or post-order breaches. |
| |
3 | Courts may fine a corporation up to 2% of annual gross turnover; individual offenses up to 245 currency points (UGX 4.9 million). |
| |
3 | Up to GBP 17.5 million or 4% of worldwide annual turnover, whichever is higher; PECR fines now aligned to the same level. |
| |
3 | Up to 5% of prior-year revenue for cross-border violations, 10x revenue for illegal data trading, VND 3 billion for other violations. |
| |
2 | Up to USD 2,663 per violation or USD 7,988 per intentional violation or violation involving minors, with no aggregate cap. |
| |
2 | Up to 2,000 monthly minimum wages (roughly USD 0.7m), plus suspension or closure of operations. |
| |
2 | Administrative fines up to USD 100,000 per standard contravention under Schedule 2. |
| |
2 | Fines up to EGP 5 million (about USD 100,000) per offense, doubled for repeat offenses. |
| |
2 | Criminal fines up to HKD 1,000,000 (about USD 128k) for doxxing causing harm or selling data for marketing. |
| |
2 | Criminal corporate fine up to JPY 100 million for violating PPC orders or unlawful database provision. Amendment adds revenue-linked administrative surcharges. |
| |
2 | Up to RM1,000,000 (about USD 235k) and/or 3 years' imprisonment for breaching the data protection principles. |
| |
2 | Up to 320,000 UMA (about MXN 36 million, roughly USD 2m), doubled for sensitive data, plus an additional fine of up to 320,000 UMA for repeat violations. |
| |
2 | Up to 100 UIT (about PEN 535,000, roughly USD 145,000), not exceeding 10% of prior-year gross income. |
| |
2 | Fines up to SAR 5 million (about USD 1.3m) per violation, doubled for repeat violations. |
| |
2 | Administrative fine up to R10 million (about USD 550,000). |
| |
2 | Criminal fine up to CHF 250,000 per individual; a company can be fined up to CHF 50,000 when identifying the individual is disproportionate. |
| |
2 | Administrative fines up to THB 5 million per violation (about USD 150k). |
| |
2 | Administrative fines up to TRY 17,092,242 per violation in 2026, revalued each year. |
| |
1 | ARS 1,000 to 100,000 per infringement; total for the same conduct capped at ARS 50 million (about USD 35,000-40,000). |
| |
1 | Fines up to CAD 100,000 on indictment (CAD 10,000 summary) for knowing breach-reporting and listed violations; no administrative fines. |
| |
1 | Court-imposed fines of 1 to 10 UTM, or 10 to 50 UTM for economic, financial and commercial data (about USD 3,500 at most). |
| |
1 | General penalty up to 5,000 penalty units (about GHS 60,000) and/or 10 years' imprisonment. |
| |
1 | Up to KES 5 million or 1% of prior-year annual turnover, whichever is lower (about USD 39,000 maximum). |
| |
1 | Criminal fines up to NZD 10,000 (e.g. failing to notify a breach). |
| |
1 | Criminal fines up to PHP 5 million; administrative fines up to 3% of annual gross income, capped at PHP 5 million (about USD 86k) per act. |
| |
1 | Up to 500,000 indexed units (UI) (roughly USD 80,000), plus warning or suspension of the database. |
| |
1 | Fines up to level 11 (reported at about USD 1,000) and/or up to 7 years' imprisonment. |
| |
0 | No fines in force; Cabinet decision defining violations and penalties not issued. |
This index, the topic tags and the notes are ours, scored on the published rubric. Headings marked "our heading" are our descriptions where the source has none. Always read the official text before acting. Not legal advice.
Regulations library
Every US state privacy law, on one map
24 states have a comprehensive privacy law in the library, alongside the EU, UK, US federal and global laws: 102 in all, each explained in plain words with its sources. Select a state to see what applies there.
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