Privacy Act

In Privacy Act

• Section 2Commencement
• Section 3Purpose of this Act
• Section 4Application of this Act

  Applies to overseas agencies carrying on business in New Zealand, even without a place of business or commercial purpose.

• Section 7Interpretation
• Section 23Application of IPPs in relation to information held overseas
• Section 26Restricted application of IPP 13 to unique identifiers assigned before 1 July 1993
• Section 27Restricted application of IPPs to personal information collected or held for personal or domestic affairs
• Section 35Commencement of code
• Section 36Application of Legislation Act 2019 to codes
• Section 39Interpretation
• Section 58Interpretation
• Section 68Interpretation
• Section 79Application of this subpart
• Section 112Interpretation
• Section 134Application of Human Rights Act 1993
• Section 138Interpretation
• Section 153When requirement to give notice of adverse action applies
• Section 164Interpretation
• Section 171Interpretation
• Section 175Application of this subpart
• Section 177Interpretation
• Section 192Interpretation
• Section 199Application of Human Rights Act 1993
• Section 209Exclusion of public interest immunity

Reach abroad across 39 laws

New Zealand Privacy Act	2	Applies to overseas agencies carrying on business in New Zealand, even without a place of business or commercial purpose.
Brazil LGPD	3	Applies regardless of location if processing occurs in Brazil, targets goods or services to people in Brazil, or data was collected in Brazil.
Egypt PDPL	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.
Ghana DPA	3	Applies to controllers in Ghana, foreign controllers using equipment or processors in Ghana, and processing of information originating in Ghana.
Indonesia PDP Law	3	Applies inside Indonesia and to acts abroad with legal effect in Indonesia or on Indonesian citizens abroad.
Kenya DPA	3	Applies to controllers and processors outside Kenya that process personal data of data subjects located in Kenya.
Nigeria NDPA	3	Applies to controllers and processors outside Nigeria processing personal data of data subjects in Nigeria.
Saudi Arabia PDPL	3	Applies to processing in the Kingdom and to processing outside it of personal data of individuals residing in the Kingdom, by any means.
Switzerland nFADP	3	Applies to any circumstances that have an effect in Switzerland, even if initiated abroad; some foreign controllers must appoint a Swiss representative.
UAE (federal) PDPL	3	Applies to controllers and processors outside the UAE that process personal data of data subjects inside the State.
Uganda DPPA	3	Applies to anyone collecting or processing personal data in Uganda, and to anyone outside Uganda handling data relating to Ugandan citizens.
Vietnam PDPL	3	Applies to foreign entities in Vietnam and to foreign entities directly processing data of Vietnamese citizens and residents in Vietnam.
Australia Privacy Act	2	Applies to organizations abroad with an Australian link, including carrying on business in Australia.
California CCPA	2	Applies to for-profit businesses doing business in California that meet revenue or data-volume thresholds, wherever located, for California residents' data.
Canada PIPEDA	2	Applies to commercial activity with a real and substantial connection to Canada, and to interprovincial or international disclosures for consideration.
China PIPL	2	Applies outside China when providing products or services to people in China or analyzing their behavior; foreign handlers need a local representative.
Ecuador LOPDP	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.
European Union GDPR	2	Applies to non-EU controllers offering goods or services to, or monitoring the behavior of, people in the EU.
India DPDP Act	2	Applies to processing outside India connected with offering goods or services to data principals in India.
Japan APPI	2	Applies to foreign businesses handling personal information of people in Japan in connection with supplying goods or services to them.
Peru Law 29733	2	Covers non-established controllers that offer goods or services to, or profile, people in Peru; they must appoint a representative.
Philippines DPA	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).
Quebec Law 25	2	Applies to enterprises collecting, holding, using or communicating personal information about people in Quebec in the course of business.
Singapore PDPA	2	Applies to organizations whether or not resident or with an office in Singapore, in practice when collecting, using or disclosing data in Singapore.
South Korea PIPA	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.
Thailand PDPA	2	Applies to controllers or processors abroad that offer goods or services to people in Thailand or monitor their behavior in Thailand.
Turkey KVKK	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.
United Kingdom UK GDPR	2	Applies to non-UK controllers offering goods or services to, or monitoring behavior of, people in the UK.
Uruguay Law 18,331	2	Applies to non-established controllers offering goods or services to, or analyzing behavior of, people in Uruguay, or using means located there.
Colombia Law 1581	1	Applies to processing in Colombia and to foreign controllers or processors when Colombian law applies under international norms or treaties.
DIFC DIFC DPL	1	Applies to controllers or processors incorporated in DIFC, and to processing in DIFC including through stable arrangements, wherever the controller sits.
Hong Kong PDPO	1	Applies to data users controlling data in or from Hong Kong; no express reach over foreign businesses targeting Hong Kong residents.
Israel PPL	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.
Malaysia PDPA	1	Applies to persons established in Malaysia, or using equipment in Malaysia other than for transit; foreign users must nominate a local representative.
Mexico LFPDPPP	1	Law applies nationwide; the Regulation also reaches non-established controllers that use means located in Mexico (other than transit).
South Africa POPIA	1	Applies to responsible parties domiciled in South Africa, or not domiciled but using automated or non-automated means in the Republic.
Zimbabwe CDPA	1	Applies to controllers active in Zimbabwe and to controllers not established there that use means located in Zimbabwe.
Argentina Law 25,326	0	No extraterritorial provision; applies to files and databases, public or private, in Argentina.
Chile Law 19,628	0	No extraterritorial provision in the current text.

In Privacy Act

• Section 22Information privacy principles
• Section 186Avoidance of controls on information matching through use of exceptions to information privacy principles

We don't score this topic in the comparison. The sections on the left are the place to start.

In Privacy Act

• Section 22Information privacy principles

  No lawful-basis list; collection must be for a lawful purpose connected to the agency's functions and necessary for it.

Lawful basis across 39 laws

New Zealand Privacy Act	1	No lawful-basis list; collection must be for a lawful purpose connected to the agency's functions and necessary for it.
Argentina Law 25,326	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.
Canada PIPEDA	3	Consent is the default basis, with limited statutory exceptions.
Chile Law 19,628	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.
Colombia Law 1581	3	Prior, express and informed authorization is required, with narrow exceptions (public authority requests, public data, medical emergencies, civil registry). No legitimate interests.
Egypt PDPL	3	Explicit consent is the default; other grounds are contract, legal obligation and exercising legal rights. No legitimate interests ground.
India DPDP Act	3	Consent is the default basis; processing without consent only for listed 'legitimate uses' (s.7). No general legitimate interests ground.
Israel PPL	3	Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.
Malaysia PDPA	3	Consent is the general rule; non-consent processing only where necessary for contract, legal obligation, vital interests, justice and similar listed grounds.
Mexico LFPDPPP	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.
Peru Law 29733	3	Consent is the default basis; exceptions listed in the Law (public entities, public sources, contracts, health, anonymized data). No legitimate interests.
Quebec Law 25	3	Consent is the default basis for use and communication, with listed exceptions.
UAE (federal) PDPL	3	Processing without consent is prohibited except in listed cases (public interest, contract, legal obligation, public data and others); no legitimate interests ground.
Uganda DPPA	3	Prior consent is the default; exceptions cover law, national security, medical purposes, legal obligation and contracts. No legitimate interests ground.
Uruguay Law 18,331	3	Consent is the default basis, with exceptions for public sources, state functions, limited listings, contracts and domestic use. No legitimate interests.
Vietnam PDPL	3	Consent is the default basis; the Law adds listed exceptions such as contract performance, legal obligations and protecting legitimate rights.
China PIPL	2	Consent or six other bases (contract/HR, legal duty, emergencies, news, public data, other laws); no legitimate interests.
Australia Privacy Act	1	No lawful-basis list; collection must be reasonably necessary, and secondary use needs consent, reasonable expectation or an exception.
Brazil LGPD	1	Ten legal bases including consent, legal obligation, contract, credit protection and legitimate interests.
DIFC DIFC DPL	1	Multiple bases including consent, contract, legal obligation, vital interests and legitimate interests.
Ecuador LOPDP	1	Eight bases including consent, legal obligation, contract, vital interests, public interest and legitimate interest.
European Union GDPR	1	Six lawful bases, including consent, contract, legal obligation, vital interests, public task and legitimate interests.
Ghana DPA	1	Prior consent or listed grounds, including contract, legal obligation, and legitimate interests of the controller or a third party.
Hong Kong PDPO	1	No lawful-basis list; collection must be lawful, fair and for a purpose directly related to the data user's functions.
Indonesia PDP Law	1	Consent, contract, legal obligation, vital interests, public interest/authority, and legitimate interests.
Japan APPI	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.
Kenya DPA	1	Consent or listed necessity grounds, including legitimate interests unless unwarranted given harm to the data subject.
Nigeria NDPA	1	Consent or listed necessity grounds, including legitimate interests unless the data subject would not reasonably expect the processing.
Philippines DPA	1	Multiple bases: consent, contract, legal obligation, vital interests, public order, public authority and legitimate interests.
Saudi Arabia PDPL	1	Consent plus other bases, including legitimate interests (since 2023 amendment) after a documented assessment; not for sensitive data.
Singapore PDPA	1	Consent, deemed consent, or exceptions in the First and Second Schedules, including a legitimate interests exception.
South Africa POPIA	1	Six lawful grounds including consent, contract, legal obligation, and legitimate interests of the responsible party or a third party.
South Korea PIPA	1	Consent, law, public duties, contract, vital interests, legitimate interests that clearly override data subject rights, and urgent public safety.
Switzerland nFADP	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.
Thailand PDPA	1	Consent or six other bases: research, vital interests, contract, public task, legitimate interests, and legal obligation.
Turkey KVKK	1	Explicit consent is the default, but processing without consent is allowed on listed grounds, including contract, legal obligation and legitimate interests.
United Kingdom UK GDPR	1	Six GDPR bases plus a new 'recognised legitimate interests' basis (Annex 1) needing no balancing test, in force 5 Feb 2026.
Zimbabwe CDPA	1	Consent or listed grounds including legal obligation, vital interests, public interest and legitimate interests of the controller or third party.
California CCPA	0	No lawful-basis requirement; notice at collection plus purpose limitation, with opt-out of sale/sharing.

In Privacy Act

• Section 22Information privacy principles

  No age threshold; collection must be fair and not unreasonably intrusive, particularly from children or young persons.

Children across 39 laws

New Zealand Privacy Act	1	No age threshold; collection must be fair and not unreasonably intrusive, particularly from children or young persons.
Brazil LGPD	3	Under 12 needs specific parental consent; all minors under 18 must be processed in their best interest.
Colombia Law 1581	3	Processing data of all minors under 18 is prohibited except public data, or with legal representative authorization respecting the child's best interests.
Egypt PDPL	3	Children's data is sensitive. Under 15 needs written guardian consent; for ages 15 to 18 the Center sets the consent mechanism.
Ghana DPA	3	Age 18 (Children's Act). Data about a child under parental control is treated as special personal data.
India DPDP Act	3	Child means under 18; verifiable parental consent required; no tracking, behavioral monitoring or targeted advertising directed at children.
Indonesia PDP Law	3	Processing children's data needs consent of parent or guardian; child means under 18 under Indonesian child law.
Kenya DPA	3	Age 18. Processing requires parent or guardian consent and must serve the child's best interests; profiling children for direct marketing is barred.
Malaysia PDPA	3	For data subjects under 18, a parent, guardian or person with parental responsibility acts and consents.
Nigeria NDPA	3	Age 18 (Child's Rights Act). Parental or guardian consent with age verification; regulations pending for electronic services to children 13 and over.
Saudi Arabia PDPL	3	No fixed age in the PDPL; legal guardians act for persons lacking full legal capacity, including minors.
South Africa POPIA	3	Child means under 18. Processing children's information is prohibited unless a s.35 exception applies, such as consent of a competent person.
Thailand PDPA	3	Minors (under 20) need guardian consent unless they could act alone; under 10 always needs guardian consent.
Uganda DPPA	3	Age 18. Processing a child's data needs prior parental or guardian consent, unless required by law or for research or statistics.
Zimbabwe CDPA	3	Age 18. Parents or guardians consent and exercise rights; controllers must verify consent and run regular DPIAs for children's data.
California CCPA	2	Under 16: opt-in required to sell/share; under 13: parental authorization. Fines up to USD 7,988 for violations involving minors under 16.
China PIPL	2	Under 14 requires parent or guardian consent and special handling rules; such data is sensitive.
Ecuador LOPDP	2	Adolescents 15 and over may consent; younger children need a legal representative; ages 12-15 exercise rights through a representative.
European Union GDPR	2	Parental consent required for information society services offered to children under 16; Member States may lower the age to no less than 13.
Peru Law 29733	2	Minors 14 to 18 may consent if information is understandable; under 14 needs parental or guardian consent; reasonable age verification required.
Quebec Law 25	2	Information about a minor under 14 requires consent from the person with parental authority, unless clearly for the minor's benefit.
South Korea PIPA	2	Under 14: legal representative consent required and must be verified.
Vietnam PDPL	2	Legal representative acts for children (under 16); child aged 7+ and representative must both consent for private-life data.
Australia Privacy Act	1	No statutory age; OAIC guidance presumes capacity at 15. Children's Online Privacy Code (under 18) due by 10 Dec 2026.
Canada PIPEDA	1	No statutory age; the OPC considers children under 13 unable to give meaningful consent.
Japan APPI	1	No statutory age today; PPC Q&A treats roughly 12-15 as needing a guardian. Amendment sets under 16 for guardian consent once in force.
Singapore PDPA	1	PDPC guidance: children 13 to 17 may consent if notices are understandable; under 13 need parent or guardian consent.
United Kingdom UK GDPR	1	Age of consent for information society services is 13; online services likely accessed by children must consider children's higher protection in design.
Argentina Law 25,326	0	No child-specific rule or age threshold in the Act; general capacity rules of the Civil and Commercial Code apply.
Chile Law 19,628	0	No child-specific rule or age threshold in the current text.
DIFC DIFC DPL	0	No children's consent age; minors are excluded from certain automated-decision exceptions.
Hong Kong PDPO	0	No age threshold or children-specific consent rule.
Israel PPL	0	No age threshold in the PPL; minors under 18 lack full legal capacity, so parental consent is generally needed.
Mexico LFPDPPP	0	No child-specific rule or age threshold; minors act through representatives under the Federal Civil Code (minority ends at 18).
Philippines DPA	0	No child-specific rule or age threshold in the Act; age is listed as sensitive personal information.
Switzerland nFADP	0	No fixed age; a minor can consent if they have capacity of judgment, assessed case by case.
Turkey KVKK	0	No specific rule; under-18s are minors under the Civil Code, so a parent or guardian generally gives consent.
UAE (federal) PDPL	0	No age threshold or child-specific rule in the Decree-Law.
Uruguay Law 18,331	0	No child-specific rule or age threshold in the Law; minors' data listed among vulnerable groups triggering a DPIA.

In Privacy Act

• Section 22Information privacy principles

  Access and correction only.

• Section 26Restricted application of IPP 13 to unique identifiers assigned before 1 July 1993
• Section 27Restricted application of IPPs to personal information collected or held for personal or domestic affairs
• Section 44Responding to IPP 6 request

  Respond no later than 20 working days after receipt (about 28 calendar days).

• Section 45Decision to grant access to personal information
• Section 46Decision to refuse access to personal information
• Section 49Protection, etc, of individual as reason for refusing access to personal information
• Section 50Evaluative material as reason for refusing access to personal information
• Section 51Security, defence, international relations as reason for refusing access to personal information
• Section 52Trade secret as reason for refusing access to personal information
• Section 53Other reasons for refusing access to personal information
• Section 54Agency may impose conditions instead of refusing access to personal information
• Section 57Responsibilities of agency before giving access to personal information
• Section 59Individuals may make correction requests
• Section 62Transfer of correction request
• Section 63Decision on request to correct personal information
• Section 64Decision on request to attach statement of correction
• Section 91Procedure after completion of investigation relating to access to personal information
• Section 92Access direction
• Section 99Right of Director to appear in proceedings commenced under section 98
• Section 104Enforcement of access direction
• Section 105Appeal to Tribunal against access direction
• Section 109Proceedings involving access to personal information
• Section 111Certain provisions of Human Rights Act 1993 to apply
• Section 134Application of Human Rights Act 1993
• Section 165Access by agencies to identity information
• Section 166Manner and form of access
• Section 172Access by accessing agencies to law enforcement information
• Section 199Application of Human Rights Act 1993

Rights across 39 laws

New Zealand Privacy Act	1	Access and correction only.
Brazil LGPD	3	Confirmation, access, correction, anonymization/blocking/deletion, portability, consent revocation, objection and review of automated decisions.
California CCPA	3	Know/access, delete, correct, portability, opt-out of sale/sharing, limit sensitive data, and ADMT opt-out and access rights.
China PIPL	3	Know and decide, restrict or refuse, access and copy, portability, correction, deletion, explanation and refusal of solely automated decisions.
DIFC DIFC DPL	3	Withdraw consent, access, rectification, erasure, objection (incl. direct marketing), restriction, portability and automated-decision rights.
Ecuador LOPDP	3	Information, access, rectification, deletion, objection, portability, suspension of processing, and not to be subject to solely automated decisions.
European Union GDPR	3	Access, rectification, erasure, restriction, portability, objection and rights on solely automated decisions.
Indonesia PDP Law	3	Information, correction, access, erasure, withdrawal, objection to automated decisions, restriction/suspension, portability and compensation.
Kenya DPA	3	Information, access, objection, correction, deletion, restriction, portability, and the right not to be subject to solely automated decisions.
Nigeria NDPA	3	Access, copy, rectification, erasure, restriction, portability, objection (absolute for direct marketing) and safeguards against solely automated decisions.
Peru Law 29733	3	Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).
Quebec Law 25	3	Access, rectification, portability, de-indexing or cessation of dissemination, consent withdrawal, and information on automated decisions.
South Africa POPIA	3	Access, correction, deletion, objection (including direct marketing), protection from solely automated decisions, and restriction in limited cases.
South Korea PIPA	3	Access, portability (transmission), correction, erasure, suspension of processing, and the right to object to or seek explanation of automated decisions.
Switzerland nFADP	3	Access, rectification, deletion, restriction/prohibition of processing, objection, data portability, and a right to be heard on automated individual decisions.
Thailand PDPA	3	Access, portability, objection, erasure, restriction and rectification.
UAE (federal) PDPL	3	Information and access, portability, correction and erasure, restriction, objection (incl. direct marketing) and rights against automated decisions.
United Kingdom UK GDPR	3	Access, rectification, erasure, restriction, portability, objection, and safeguards on significant automated decisions, plus a right to complain to the controller.
Argentina Law 25,326	2	Access, rectification, updating and suppression; removal or blocking of marketing data at any time.
Chile Law 19,628	2	Information (access), modification, deletion and blocking; opposition to use for advertising, market research or surveys.
Colombia Law 1581	2	Know, update and correct data; proof of authorization; information on use; complain to SIC; revoke authorization or request deletion.
Egypt PDPL	2	Know and access data, withdraw consent, correct and erase, restrict processing, object, and be told of breaches.
Ghana DPA	2	Access, correction and deletion, the right to prevent processing, direct marketing opt-out, and rights against solely automated decisions.
Israel PPL	2	Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
Japan APPI	2	Disclosure (access), correction/deletion, cessation of use or erasure, cessation of third-party provision, and disclosure of third-party provision records.
Malaysia PDPA	2	Access, correction, withdrawal of consent, prevent damaging processing, stop direct marketing and data portability.
Mexico LFPDPPP	2	ARCO rights: access, rectification, cancellation and opposition, including objection to automated processing with significant effects. No portability right.
Philippines DPA	2	Right to be informed, access, rectification, erasure or blocking, objection (incl. direct marketing), portability and damages.
Saudi Arabia PDPL	2	Rights to be informed, access and copy, correction, restriction and destruction; no portability right.
Turkey KVKK	2	Learn whether data is processed and get information (access), rectification, erasure, notice to third-party recipients, objection to solely automated outcomes, and compensation.
Uganda DPPA	2	Access, correction and deletion, objection to damaging processing, direct marketing opt-out, and rights against solely automated decisions.
Uruguay Law 18,331	2	Access, rectification, updating, inclusion, suppression; challenge automated decisions; removal or blocking of marketing data.
Vietnam PDPL	2	Be informed, consent and withdraw, access, correction, deletion, restriction, objection, complaint and lawsuit.
Zimbabwe CDPA	2	Information, access, objection, correction and deletion of false data, and protection from solely automated decisions.
Australia Privacy Act	1	Access and correction; no statutory erasure, portability or objection rights (direct marketing opt-out aside).
Canada PIPEDA	1	Access, correction, and withdrawal of consent; no statutory deletion, portability or automated-decision rights.
Hong Kong PDPO	1	Access and correction only.
India DPDP Act	1	Access to information, correction, completion, updating and erasure, grievance redressal and nomination. No portability, objection or automated-decision rights.
Singapore PDPA	1	Access and correction; data portability enacted but not yet in force; right to withdraw consent.

In Privacy Act

• Section 201Privacy officers

  Every agency must appoint one or more privacy officers.

DPO required across 39 laws

New Zealand Privacy Act	3	Every agency must appoint one or more privacy officers.
Canada PIPEDA	3	Every organization must designate an individual accountable for compliance.
Colombia Law 1581	3	Every controller and processor must designate a person or area to assume the data protection function and handle requests.
Egypt PDPL	3	Every legal-entity controller and processor must appoint a qualified employee as DPO and register them with the Center.
Mexico LFPDPPP	3	Every controller must designate a person or data protection department to handle ARCO requests and promote data protection internally.
Philippines DPA	3	Every personal information controller and processor must designate a DPO or accountable individual, and register one DPO.
Quebec Law 25	3	The person with highest authority in every enterprise is by default the person in charge of personal information protection; may delegate in writing.
Singapore PDPA	3	Every organization must designate one or more individuals responsible for PDPA compliance and publish business contact information.
South Africa POPIA	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.
South Korea PIPA	3	Every controller must designate a chief privacy officer; small businesses default to the owner or representative.
Uganda DPPA	3	The head of every institution covered by the Act must designate a data protection officer.
Zimbabwe CDPA	3	Every data controller must appoint a DPO and notify POTRAZ on Form DP2.
Brazil LGPD	2	Controllers must appoint an encarregado; ANPD may exempt small processing agents.
Ghana DPA	2	Statute lets controllers appoint a certified data protection supervisor; DPC guidance requires medium and large controllers to appoint one.
Nigeria NDPA	2	Data controllers and processors of major importance must designate a DPO; low thresholds (over 200 data subjects in six months) capture many firms.
Vietnam PDPL	2	Must appoint qualified data protection personnel or department, or hire a service provider.
Australia Privacy Act	1	Not required for organizations; Australian Government agencies must appoint a privacy officer under the Agencies Code.
China PIPL	1	Handlers processing personal information above the volume set by the CAC must appoint a personal information protection officer.
DIFC DIFC DPL	1	DPO required for DIFC Bodies and for controllers or processors performing high-risk processing on a systematic or regular basis.
Ecuador LOPDP	1	DPO required for public-sector processing, large-scale systematic monitoring and large-scale processing of special categories.
European Union GDPR	1	DPO required for public bodies, large-scale systematic monitoring, or large-scale special-category or criminal data processing.
India DPDP Act	1	Only Significant Data Fiduciaries notified by the government must appoint a DPO; others publish contact of a DPO or responsible person.
Indonesia PDP Law	1	DPO required for public-service processing, large-scale systematic monitoring, or large-scale specific/criminal data; any one trigger suffices.
Israel PPL	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.
Kenya DPA	1	Controllers and processors may appoint a DPO for public or private bodies, systematic monitoring, or sensitive data processing.
Malaysia PDPA	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.
Peru Law 29733	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.
Saudi Arabia PDPL	1	DPO required for public entities processing at large scale, and where core activities involve systematic monitoring or sensitive data.
Switzerland nFADP	1	Optional for private controllers; federal bodies must appoint a data protection advisor.
Thailand PDPA	1	DPO required for public authorities, large-scale regular monitoring, or core activities involving sensitive data.
UAE (federal) PDPL	1	DPO required for high-risk processing, systematic assessment of sensitive data including profiling, or large-volume sensitive data.
United Kingdom UK GDPR	1	DPO required for public authorities, large-scale systematic monitoring, or large-scale special-category or criminal data processing.
Uruguay Law 18,331	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.
California CCPA	0	No DPO requirement; executive accountable for risk-assessment attestations and cybersecurity audit certification.
Hong Kong PDPO	0	No DPO requirement.
Japan APPI	0	No DPO requirement; controllers must take necessary security control measures, including organizational measures.
Turkey KVKK	0	No DPO requirement; registered controllers must appoint a contact person for the Authority and data subjects.
Argentina Law 25,326	–	Not addressed
Chile Law 19,628	–	Not addressed

In Privacy Act

• Section 28IPPs 2, 3, 3A, and 4(b) do not apply to collection of personal information by intelligence and security agencies
• Section 51Security, defence, international relations as reason for refusing access to personal information
• Section 95Special procedure relating to intelligence and security agency

We don't score this topic in the comparison. The sections on the left are the place to start.

In Privacy Act

• Section 30Commissioner may authorise collection, use, storage, or disclosure of personal information otherwise in breach of IPP 2 or IPPs 9 to 12
• Section 96Commissioner to report breach of duty or misconduct
• Section 113Assessment of likelihood of serious harm being caused by privacy breach
• Section 114Agency to notify Commissioner of notifiable privacy breach

  Notify the Commissioner as soon as practicable after becoming aware of a notifiable breach (OPC guide: within 72 hours).

• Section 115Agency to notify affected individual or give public notice of notifiable privacy breach

  Notify affected individuals as soon as practicable where serious harm is likely, or give public notice.

• Section 116Exceptions to or delay in complying with requirement to notify affected individuals or give public notice of notifiable privacy breach
• Section 119Section 211 does not apply to processes and proceedings relating to failure to notify notifiable privacy breach

Tell the regulator across 39 laws

New Zealand Privacy Act	1	Notify the Commissioner as soon as practicable after becoming aware of a notifiable breach (OPC guide: within 72 hours).
China PIPL	3	Immediately take remedial measures and notify the regulator of a leak, alteration or loss.
India DPDP Act	3	Intimate the Board without delay, then a detailed report within 72 hours of becoming aware.
Israel PPL	3	Report a severe security incident to the PPA immediately on discovery, through its online form.
Uganda DPPA	3	Notify the PDPO immediately on believing data was accessed or acquired by an unauthorized person.
Zimbabwe CDPA	3	Notify POTRAZ within 24 hours of becoming aware, on Form DP3; investigation report within 21 days.
Brazil LGPD	2	Notify ANPD within 3 business days of learning an incident affected personal data and may cause relevant risk or harm.
California CCPA	2	Notify the Attorney General within 15 days of notifying consumers when a breach affects more than 500 California residents.
Colombia Law 1581	2	Report security incidents to SIC through the RNBD within 15 business days of detection.
Ecuador LOPDP	2	Notify the Superintendency within 5 days of becoming aware, unless the breach is unlikely to create risk; processors tell controllers within 2 days.
Egypt PDPL	2	Notify the Center within 72 hours of becoming aware; national-security breaches immediately.
European Union GDPR	2	Notify the supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware, unless risk is unlikely.
Indonesia PDP Law	2	Written notice to the agency within 72 hours (3x24 hours) after a failure is established.
Japan APPI	2	Report reportable breaches (sensitive data, financial harm, improper purpose, over 1,000 persons) promptly (3-5 days guidance), final report within 30 days, 60 if malicious.
Kenya DPA	2	Notify the Data Commissioner within 72 hours of becoming aware where there is a real risk of harm; processors tell controllers within 48 hours.
Malaysia PDPA	2	Notify the Commissioner as soon as practicable and within 72 hours of the breach.
Nigeria NDPA	2	Notify the Commission within 72 hours of becoming aware of a breach likely to risk individuals' rights.
Peru Law 29733	2	Notify the Authority within 48 hours of qualifying incidents (large-scale, sensitive data or many affected); digital incidents also to the National Digital Security Center.
Philippines DPA	2	Notify the NPC within 72 hours of knowledge of a breach involving sensitive or fraud-enabling data with real risk of serious harm.
Saudi Arabia PDPL	2	Notify SDAIA within 72 hours of becoming aware of a breach that may harm data subjects.
Singapore PDPA	2	After assessing a breach as notifiable, notify the PDPC as soon as practicable and no later than 3 calendar days.
South Korea PIPA	2	Report to PIPC within 72 hours where 1,000+ persons, sensitive or unique identifiers, or external hacking are involved.
Thailand PDPA	2	Notify the PDPC Office within 72 hours of becoming aware, where feasible, unless no risk to rights.
Turkey KVKK	2	Notify the Board as soon as possible, interpreted by the Board as within 72 hours of discovery, with no risk threshold.
United Kingdom UK GDPR	2	Notify the ICO without undue delay and, where feasible, within 72 hours of becoming aware, unless risk is unlikely.
Uruguay Law 18,331	2	Notify the URCDP within 72 hours of becoming aware of a breach, then file a detailed report once resolved.
Vietnam PDPL	2	Notify the specialized agency (A05) within 72 hours of detecting a breach likely to cause serious harm.
Australia Privacy Act	1	Assess suspected breaches within 30 days; notify OAIC as soon as practicable for eligible data breaches.
Canada PIPEDA	1	Report to the Commissioner as soon as feasible if a breach creates a real risk of significant harm.
DIFC DIFC DPL	1	Notify the Commissioner as soon as practicable in the circumstances; no fixed hours.
Ghana DPA	1	Notify the Commission as soon as reasonably practicable after discovery; no fixed hour limit.
Quebec Law 25	1	Promptly notify the Commission d'accès à l'information of incidents presenting a risk of serious injury.
South Africa POPIA	1	Notify the Regulator as soon as reasonably possible after discovering a security compromise; no fixed hour limit. Filed through the eServices portal since April 2025.
Switzerland nFADP	1	Notify the FDPIC as soon as possible of a breach likely to pose a high risk; no fixed hour deadline.
UAE (federal) PDPL	1	Notify the Data Office on becoming aware of a breach prejudicing privacy, within a period the Executive Regulations will set.
Argentina Law 25,326	0	No statutory breach notification duty.
Chile Law 19,628	0	No breach notification duty in the current text.
Hong Kong PDPO	0	No mandatory notification; voluntary notice to PCPD encouraged.
Mexico LFPDPPP	0	No duty to notify the regulator.

In Privacy Act

• Section 9Meaning of overseas agency
• Section 22Information privacy principles

  Overseas disclosure allowed only with comparable safeguards, consent after warning, prescribed binding scheme or country, or contract.

• Section 23Application of IPPs in relation to information held overseas
• Section 43Transfer of IPP 6 request
• Section 62Transfer of correction request
• Section 76Referral of complaint to overseas privacy enforcement authority
• Section 193Prohibition on transfer of personal information outside New Zealand
• Section 195Transfer prohibition notice
• Section 196Commissioner may vary or cancel transfer prohibition notice
• Section 197Offence in relation to transfer prohibition notice
• Section 198Appeals against transfer prohibition notice
• Section 207Commissioner may share information with overseas privacy enforcement authority

Transfers abroad across 39 laws

New Zealand Privacy Act	2	Overseas disclosure allowed only with comparable safeguards, consent after warning, prescribed binding scheme or country, or contract.
China PIPL	3	Transfers need CAC security assessment, certification or the CAC standard contract, plus notice and separate consent.
Egypt PDPL	3	Transfers abroad need equivalent protection in the destination and a licence or permit from the Center, unless a listed exception applies.
Vietnam PDPL	3	Transfer impact assessment dossier must be filed with MPS within 60 days of first transfer, plus a written agreement with the recipient.
Argentina Law 25,326	2	Transfers prohibited to countries or bodies without adequate protection, except listed cases such as treaties, judicial cooperation and other statutory exceptions.
Brazil LGPD	2	Transfers allowed via adequacy, ANPD standard clauses (mandatory since Aug 2025), ANPD-approved specific clauses or BCRs, or specific consent.
Colombia Law 1581	2	Transfers to countries without adequate protection are prohibited unless an exception applies (explicit consent, contract, treaty) or SIC issues a declaration of conformity.
DIFC DIFC DPL	2	Transfer if destination has adequate protection or with appropriate safeguards, or listed derogations.
Ecuador LOPDP	2	Transfers allowed to countries declared adequate by the regulator, or with binding guarantees or binding corporate rules; listed exceptions include explicit consent.
European Union GDPR	2	Transfers outside the EEA need an adequacy decision or appropriate safeguards (SCCs, BCRs), or a listed derogation.
Indonesia PDP Law	2	Destination must offer equal or higher protection, else adequate binding safeguards, else consent; BCRs need DPA approval under GR 33.
Israel PPL	2	Allowed only if the destination's protection is no lower than Israel's, or under listed exceptions such as consent, EU-adequate or Convention 108 countries, group or contractual safeguards; no PPA approval.
Japan APPI	2	Transfer abroad needs prior consent after information on the destination regime, an adequate country (EU/UK), or a recipient with equivalent systems.
Kenya DPA	2	Transfers need proof of appropriate safeguards to the Data Commissioner or a listed condition; sensitive data needs consent.
Malaysia PDPA	2	Transfer allowed if destination law is substantially similar or protection equivalent, or under listed exceptions (consent, contract, due diligence).
Mexico LFPDPPP	2	Domestic and international transfers need consent via the privacy notice, with listed exceptions; recipient assumes the controller's obligations, typically by contract.
Nigeria NDPA	2	Transfers need an adequate level of protection in the destination or a listed basis such as informed consent.
Peru Law 29733	2	Transfers allowed to adequate countries or with safeguards such as model clauses; every cross-border flow must be notified to the Authority.
Quebec Law 25	2	Before communicating data outside Quebec, conduct a PIA confirming adequate protection and sign a written agreement.
Saudi Arabia PDPL	2	Transfers need a specified purpose, minimum data, and adequacy, BCRs, standard clauses, certification or listed derogations, with a risk assessment.
Singapore PDPA	2	Transfers only under prescribed requirements ensuring a comparable standard of protection (contracts, BCRs, certification, consent).
South Africa POPIA	2	Transfers abroad allowed only with adequate protection (law, binding corporate rules or agreement), consent, contract necessity, or data subject benefit.
South Korea PIPA	2	Transfer abroad needs separate consent, a statutory basis, contract necessity with disclosure, a certified recipient, or a PIPC-recognized country.
Switzerland nFADP	2	Allowed to Federal Council-listed adequate countries; otherwise FDPIC-recognized SCCs, FDPIC-approved BCRs, or notified clauses; limited derogations such as explicit consent.
Thailand PDPA	2	Destination must have adequate standards, or a listed exception applies (consent, contract, etc.); intra-group transfers need a PDPC-certified policy.
Turkey KVKK	2	Needs a Board adequacy decision; else Board-approved BCRs or undertakings, or a Board standard contract filed within five business days. Incidental transfers allowed on listed grounds.
UAE (federal) PDPL	2	Transfer to countries with adequate protection approved by the Data Office, or via contract, explicit consent and other listed grounds.
Uganda DPPA	2	Processing or storage abroad requires adequate protection at least equivalent to the Act, or data subject consent; onward transfer needs express consent.
United Kingdom UK GDPR	2	Transfers need UK adequacy regulations under a 'not materially lower' data protection test, or appropriate safeguards such as the IDTA or Addendum.
Uruguay Law 18,331	2	Transfers prohibited to countries without adequate protection, except listed cases (explicit consent, contract, vital interest); URCDP may authorize transfers with safeguards.
Zimbabwe CDPA	2	Transfers abroad need adequate protection in the recipient country or a listed derogation such as unambiguous consent.
Australia Privacy Act	1	Take reasonable steps so overseas recipients comply with APPs; discloser stays accountable. Whitelist power added in 2024.
Canada PIPEDA	1	Organization remains accountable and must use contracts or other means to ensure comparable protection by third-party processors.
Ghana DPA	1	No general transfer restriction; controllers must ensure foreign processors comply and list transfer countries at registration.
Philippines DPA	1	No adequacy regime; controller stays accountable for data sent abroad and must ensure comparable protection by contract or other means.
Chile Law 19,628	0	No international transfer restriction in the current text.
Hong Kong PDPO	0	No transfer restriction in force; s.33 never commenced. PCPD recommends model contract clauses.
India DPDP Act	0	Transfers allowed except to countries the government restricts by notification; conditions may be set by order.
California CCPA	–	Not addressed

In Privacy Act

• Section 22Information privacy principles

  Do not keep information longer than required for lawful purposes.

Retention across 39 laws

New Zealand Privacy Act	1	Do not keep information longer than required for lawful purposes.
India DPDP Act	3	Erase when purpose ends or consent is withdrawn; large e-commerce, gaming and social platforms must erase after three years of inactivity with 48 hours' notice.
Nigeria NDPA	3	Without a statutory period, storage must end within six months after the purpose is accomplished.
Australia Privacy Act	2	Destroy or de-identify personal information once no longer needed for any permitted purpose.
Brazil LGPD	2	Data must be deleted when processing ends, with listed exceptions such as legal obligations or research.
California CCPA	2	Disclose retention period per category and keep data no longer than reasonably necessary for the disclosed purpose.
China PIPL	2	Retain for the shortest period necessary; delete when purpose is achieved, consent withdrawn or retention period expires.
DIFC DIFC DPL	2	Keep data no longer than necessary; when the basis ends, delete, anonymize, pseudonymize, encrypt or put it beyond use.
Egypt PDPL	2	Data may not be kept longer than the purpose requires and must be erased when the purpose ends.
Ghana DPA	2	Data may not be kept longer than necessary and must then be destroyed, deleted or de-identified.
Hong Kong PDPO	2	Do not keep data longer than necessary and take practicable steps to erase it.
Indonesia PDP Law	2	Delete or destroy data at the end of the retention period or on request; notices must state the retention period.
Kenya DPA	2	Keep data only as long as reasonably necessary, maintain a retention schedule with periodic review, then erase or anonymize.
Malaysia PDPA	2	Do not keep data longer than necessary and take reasonable steps to destroy or permanently delete it.
Mexico LFPDPPP	2	Data must be blocked, then deleted, once purposes end; records of contractual defaults must be deleted after 72 months.
Peru Law 29733	2	Indefinite retention generally prohibited; processors keep data at most 2 years after the engagement ends; access logs kept at least 2 years.
Quebec Law 25	2	Destroy or anonymize information once its purposes are achieved, subject to legal retention periods.
Saudi Arabia PDPL	2	Destroy data when no longer needed for its purpose or processed unlawfully, subject to legal retention exceptions.
South Africa POPIA	2	Records may not be kept longer than necessary for the purpose and must be destroyed, deleted or de-identified afterward.
South Korea PIPA	2	Destroy personal information without delay once the retention period ends or the purpose is achieved.
Thailand PDPA	2	Controllers must examine and erase or anonymize data after the retention period or when no longer needed.
Turkey KVKK	2	Erase, destroy or anonymize data once processing grounds end; registered controllers need a retention policy and periodic destruction at least every six months.
Uganda DPPA	2	Data may not be kept longer than necessary; at expiry it must be destroyed, deleted or de-identified.
Uruguay Law 18,331	2	Delete data once no longer necessary; negative credit records limited to 5 years, renewable once.
Vietnam PDPL	2	Delete when purpose is complete, retention period ends, ordered by authorities, or on request.
Argentina Law 25,326	1	Data must be destroyed once no longer necessary or relevant to the purpose collected.
Canada PIPEDA	1	Keep information only as long as needed for its purposes; destroy, erase or anonymize when no longer required.
Chile Law 19,628	1	Data must be deleted or cancelled when storage lacks a legal basis or the data has expired.
Colombia Law 1581	1	Process data only as long as reasonable and necessary for the purpose, then delete unless law or contract requires retention.
Ecuador LOPDP	1	Data kept no longer than necessary; controllers must set deletion or periodic review deadlines; the regulator may set periods.
European Union GDPR	1	Storage limitation: keep identifiable data no longer than necessary; erase when no longer needed.
Israel PPL	1	Delete data once its lawful purpose is exhausted and review holdings periodically, at least annually, for excess data; no statutory periods.
Japan APPI	1	Businesses must endeavor to delete personal data without delay once it is no longer needed.
Philippines DPA	1	Retain only as long as necessary for the declared purpose, legal claims or legitimate business purposes, then dispose securely.
Singapore PDPA	1	Cease retention or anonymize once the purpose is no longer served and no legal or business need remains.
Switzerland nFADP	1	Destroy or anonymize personal data once it is no longer needed for its purpose; no statutory periods.
UAE (federal) PDPL	1	Personal data must not be kept after the purpose is exhausted, unless anonymized.
United Kingdom UK GDPR	1	Storage limitation: keep identifiable data no longer than necessary.
Zimbabwe CDPA	1	Data may be kept no longer than necessary for the purpose collected; no specific periods.

In Privacy Act

• Section 8Meaning of New Zealand agency
• Section 9Meaning of overseas agency
• Section 10Personal information held by agency if held by officer, employee, or member of agency
• Section 11Personal information treated as being held by another agency in certain circumstances
• Section 12Actions of, and disclosure of information to, staff of agency, etc
• Section 13Privacy Commissioner
• Section 14Deputy Privacy Commissioner
• Section 15Holding of other offices
• Section 16Superannuation or retiring allowances
• Section 17Functions of Commissioner
• Section 18Other functions of Commissioner
• Section 19Responsible Minister must present copy of report on operation of Act to House of Representatives
• Section 20Duty to act independently
• Section 21Commissioner to have regard to certain matters
• Section 30Commissioner may authorise collection, use, storage, or disclosure of personal information otherwise in breach of IPP 2 or IPPs 9 to 12
• Section 54Agency may impose conditions instead of refusing access to personal information
• Section 57Responsibilities of agency before giving access to personal information
• Section 67Commissioner may authorise public sector agency to impose charge
• Section 74Commissioner may decide not to investigate complaint
• Section 76Referral of complaint to overseas privacy enforcement authority
• Section 78Referral of complaint to Director without conducting investigation
• Section 82Commissioner may regulate own procedure
• Section 84Referral of complaint to Director without completing investigation
• Section 95Special procedure relating to intelligence and security agency
• Section 96Commissioner to report breach of duty or misconduct
• Section 97Director may commence proceedings in Tribunal
• Section 98Aggrieved individuals may commence proceedings in Tribunal
• Section 99Right of Director to appear in proceedings commenced under section 98
• Section 105Appeal to Tribunal against access direction
• Section 107Interim order suspending Commissioner's direction pending appeal
• Section 114Agency to notify Commissioner of notifiable privacy breach
• Section 115Agency to notify affected individual or give public notice of notifiable privacy breach
• Section 118Offence to fail to notify Commissioner
• Section 126Agency response to compliance notice
• Section 127Commissioner may vary or cancel compliance notice
• Section 128Commissioner's power to obtain information
• Section 131Appeal against compliance notice or Commissioner's decision to vary or cancel notice
• Section 135Commissioner may be represented in proceedings
• Section 143Lead agency
• Section 145Governor-General may approve information sharing agreement by Order in Council
• Section 146Requirements for Order in Council
• Section 147Further provisions about Order in Council
• Section 149Matters to which relevant Minister must have regard before recommending Order in Council
• Section 151Commissioner may prepare and publish report on approved information sharing agreement
• Section 154Responsibilities of lead agency
• Section 155Report of lead agency
• Section 156Commissioner may specify frequency of reporting by lead agency
• Section 161Power to amend Schedule 2 by Order in Council
• Section 167Annual reporting requirement
• Section 168Power to amend Schedule 3 by Order in Council
• Section 173Power to amend Schedule 4 by Order in Council
• Section 188Power to amend Schedule 5 by Order in Council
• Section 189Power to amend Schedule 6 by Order in Council
• Section 194Commissioner's power to obtain information
• Section 196Commissioner may vary or cancel transfer prohibition notice
• Section 200Power to amend Schedule 8 by Order in Council
• Section 201AResponsibility under Parts 4 to 6 for interdepartmental executive board
• Section 202Commissioner may require agency to supply information
• Section 206Commissioner and staff to maintain secrecy
• Section 207Commissioner may share information with overseas privacy enforcement authority

We don't score this topic in the comparison. The sections on the left are the place to start.

In Privacy Act

• Section 68Interpretation
• Section 69Interference with privacy of individual
• Section 70Complaints
• Section 71Who may make complaint
• Section 72Form of complaint
• Section 73Procedure on receipt of complaint
• Section 74Commissioner may decide not to investigate complaint
• Section 75Referral of complaint to another person
• Section 76Referral of complaint to overseas privacy enforcement authority
• Section 77Exploring possibility of settlement and assurance without investigating complaint
• Section 78Referral of complaint to Director without conducting investigation
• Section 80Commencing investigation
• Section 81Conducting investigation
• Section 83Exploring possibility of settlement and assurance during investigation
• Section 84Referral of complaint to Director without completing investigation
• Section 85Compulsory conferences of parties to complaint
• Section 91Procedure after completion of investigation relating to access to personal information
• Section 93Procedure after completion of investigation relating to charging
• Section 94Procedure after completion of other investigations
• Section 98Aggrieved individuals may commence proceedings in Tribunal

  After a Commissioner complaint, individuals may bring proceedings in the Human Rights Review Tribunal for damages.

• Section 100Apology not admissible except for assessment of remedies
• Section 102Remedies in respect of interference with privacy
• Section 103Damages

  After a Commissioner complaint, individuals may bring proceedings in the Human Rights Review Tribunal for damages.

• Section 104Enforcement of access direction
• Section 105Appeal to Tribunal against access direction
• Section 106Time for lodging appeal
• Section 107Interim order suspending Commissioner's direction pending appeal
• Section 108Determination of appeal
• Section 130Enforcement of compliance notice
• Section 131Appeal against compliance notice or Commissioner's decision to vary or cancel notice
• Section 132Interim order suspending compliance notice pending appeal
• Section 133Remedies, costs, and enforcement
• Section 145Governor-General may approve information sharing agreement by Order in Council
• Section 146Requirements for Order in Council
• Section 147Further provisions about Order in Council
• Section 149Matters to which relevant Minister must have regard before recommending Order in Council
• Section 161Power to amend Schedule 2 by Order in Council
• Section 168Power to amend Schedule 3 by Order in Council
• Section 169Purpose of this subpart
• Section 170Relationship between this subpart and other law relating to information disclosure
• Section 171Interpretation
• Section 172Access by accessing agencies to law enforcement information
• Section 173Power to amend Schedule 4 by Order in Council
• Section 188Power to amend Schedule 5 by Order in Council
• Section 189Power to amend Schedule 6 by Order in Council
• Section 198Appeals against transfer prohibition notice
• Section 200Power to amend Schedule 8 by Order in Council
• Section 207Commissioner may share information with overseas privacy enforcement authority

Private action across 39 laws

New Zealand Privacy Act	2	After a Commissioner complaint, individuals may bring proceedings in the Human Rights Review Tribunal for damages.
Brazil LGPD	3	Controllers and processors must compensate material or moral damage; individual and collective actions allowed.
California CCPA	3	Private right of action for data breaches from failure to maintain reasonable security: USD 107-799 per consumer per incident, class actions allowed.
China PIPL	3	Tort claims with presumed fault of the handler; prosecutors and designated organizations may bring public interest suits.
European Union GDPR	3	Right to compensation for material or non-material damage; representative bodies may bring claims, including collective redress.
Israel PPL	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.
Quebec Law 25	3	Courts must award punitive damages of at least CAD 1,000 for intentional or grossly negligent infringements; class actions available.
South Korea PIPA	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.
Thailand PDPA	3	Strict liability for damages, plus punitive damages up to twice actual damages; class actions available under civil procedure.
Argentina Law 25,326	2	Habeas data court action to access, rectify, suppress or keep data confidential; liability for damages also arises.
Australia Privacy Act	2	Statutory tort for serious invasions of privacy (from 10 Jun 2025); representative complaints to OAIC.
Chile Law 19,628	2	Controller must compensate material and moral damage from improper processing; amount set by the judge.
Colombia Law 1581	2	Data subjects complain to SIC after exhausting the controller process; damages are claimed under general civil liability.
DIFC DIFC DPL	2	Data subjects may sue directly in DIFC Courts for financial and non-financial harm, including distress.
Ecuador LOPDP	2	Data subjects may sue for damages (Constitution art. 92 habeas data) and must be guaranteed full reparation.
Egypt PDPL	2	Victims keep the right to claim compensation; entities are jointly liable for employees' violations.
Ghana DPA	2	Individuals who suffer damage or distress from a contravention are entitled to compensation, subject to a reasonable care defense.
Hong Kong PDPO	2	Individuals suffering damage, including injury to feelings, may claim compensation; PCPD may give legal assistance.
Indonesia PDP Law	2	Data subjects may sue for compensation for violations of processing.
Japan APPI	2	Individuals may sue to compel disclosure, correction or cessation, and claim tort damages under the Civil Code.
Kenya DPA	2	Persons who suffer damage, including distress, are entitled to compensation from the controller or processor.
Mexico LFPDPPP	2	Administrative sanctions apply without prejudice to civil liability, so data subjects can claim damages in the civil courts.
Nigeria NDPA	2	Data subjects who suffer injury, loss or harm may sue for damages; the Commission can also order compensation.
Peru Law 29733	2	Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action.
Philippines DPA	2	Data subjects may be indemnified for damages from inaccurate or unlawful processing.
Saudi Arabia PDPL	2	Anyone harmed may seek proportionate compensation for material or moral damage before the competent court.
Singapore PDPA	2	Persons suffering loss or damage may sue for injunction, declaration, damages or other relief.
South Africa POPIA	2	Data subjects, or the Regulator on their behalf, may sue for patrimonial, non-patrimonial and aggravated damages, regardless of intent or negligence.
Switzerland nFADP	2	Data subjects can sue for injunctions, rectification or deletion, damages, moral damages and surrender of profits.
Turkey KVKK	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.
Uganda DPPA	2	A data subject who suffers damage or distress may apply to court for compensation; complaints also go to the PDPO.
United Kingdom UK GDPR	2	Individuals can claim compensation for material or non-material damage; representative actions are limited in practice.
Uruguay Law 18,331	2	Habeas data court action with summary procedure to access, rectify, include or delete data.
Vietnam PDPL	2	Violators must compensate damage; controllers and processors liable for losses caused by their processing.
Canada PIPEDA	1	After a Commissioner complaint, individuals may apply to the Federal Court for damages, including for humiliation.
India DPDP Act	1	Civil courts barred; data principals complain to the Data Protection Board after exhausting grievance redressal. No compensation provision.
UAE (federal) PDPL	1	Data subjects may complain to the Data Office; no compensation or civil claim provision.
Zimbabwe CDPA	1	No statutory compensation right; data subjects complain to POTRAZ, with appeal to the Administrative Court.
Malaysia PDPA	0	No statutory right for data subjects to sue for compensation; complaints go to the Commissioner.

In Privacy Act

• Section 118Offence to fail to notify Commissioner

  Criminal fines up to NZD 10,000 (e.g. failing to notify a breach).

• Section 197Offence in relation to transfer prohibition notice
• Section 212Offences

  Criminal fines up to NZD 10,000 (e.g. failing to notify a breach).

Maximum fine across 39 laws

New Zealand Privacy Act	1	Criminal fines up to NZD 10,000 (e.g. failing to notify a breach).
Australia Privacy Act	3	Body corporate: greater of AUD 50 million, 3x the benefit, or 30% of adjusted turnover for serious interferences.
Brazil LGPD	3	Simple fine up to 2% of Brazil revenue for the prior year, capped at BRL 50 million per infraction; daily fines also possible.
China PIPL	3	Up to RMB 50 million or 5% of prior-year revenue; responsible individuals RMB 100,000 to 1 million.
Ecuador LOPDP	3	Serious infringements: 0.7% to 1% of prior-year business volume; public servants 10 to 20 basic salaries.
European Union GDPR	3	Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher.
India DPDP Act	3	Up to INR 250 crore (about USD 30m) per instance for security safeguard failures.
Indonesia PDP Law	3	Administrative fines up to 2% of annual revenue; criminal corporate fines up to 10x individual maximum.
Israel PPL	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.
Nigeria NDPA	3	Greater of N10 million or 2% of prior-year annual gross revenue for entities of major importance; N2 million or 2% for others.
Quebec Law 25	3	Penal fines up to CAD 25 million or 4% of worldwide turnover; administrative penalties up to CAD 10 million or 2%.
Singapore PDPA	3	Up to 10% of annual Singapore turnover if over SGD 10 million, otherwise SGD 1 million.
South Korea PIPA	3	Penalty surcharge up to 3% of total revenue (excluding unrelated revenue); up to 10% for repeat, mass (10m+) or post-order breaches.
Uganda DPPA	3	Courts may fine a corporation up to 2% of annual gross turnover; individual offenses up to 245 currency points (UGX 4.9 million).
United Kingdom UK GDPR	3	Up to GBP 17.5 million or 4% of worldwide annual turnover, whichever is higher; PECR fines now aligned to the same level.
Vietnam PDPL	3	Up to 5% of prior-year revenue for cross-border violations, 10x revenue for illegal data trading, VND 3 billion for other violations.
California CCPA	2	Up to USD 2,663 per violation or USD 7,988 per intentional violation or violation involving minors, with no aggregate cap.
Colombia Law 1581	2	Up to 2,000 monthly minimum wages (roughly USD 0.7m), plus suspension or closure of operations.
DIFC DIFC DPL	2	Administrative fines up to USD 100,000 per standard contravention under Schedule 2.
Egypt PDPL	2	Fines up to EGP 5 million (about USD 100,000) per offense, doubled for repeat offenses.
Hong Kong PDPO	2	Criminal fines up to HKD 1,000,000 (about USD 128k) for doxxing causing harm or selling data for marketing.
Japan APPI	2	Criminal corporate fine up to JPY 100 million for violating PPC orders or unlawful database provision. Amendment adds revenue-linked administrative surcharges.
Malaysia PDPA	2	Up to RM1,000,000 (about USD 235k) and/or 3 years' imprisonment for breaching the data protection principles.
Mexico LFPDPPP	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.
Peru Law 29733	2	Up to 100 UIT (about PEN 535,000, roughly USD 145,000), not exceeding 10% of prior-year gross income.
Saudi Arabia PDPL	2	Fines up to SAR 5 million (about USD 1.3m) per violation, doubled for repeat violations.
South Africa POPIA	2	Administrative fine up to R10 million (about USD 550,000).
Switzerland nFADP	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.
Thailand PDPA	2	Administrative fines up to THB 5 million per violation (about USD 150k).
Turkey KVKK	2	Administrative fines up to TRY 17,092,242 per violation in 2026, revalued each year.
Argentina Law 25,326	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).
Canada PIPEDA	1	Fines up to CAD 100,000 on indictment (CAD 10,000 summary) for knowing breach-reporting and listed violations; no administrative fines.
Chile Law 19,628	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).
Ghana DPA	1	General penalty up to 5,000 penalty units (about GHS 60,000) and/or 10 years' imprisonment.
Kenya DPA	1	Up to KES 5 million or 1% of prior-year annual turnover, whichever is lower (about USD 39,000 maximum).
Philippines DPA	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.
Uruguay Law 18,331	1	Up to 500,000 indexed units (UI) (roughly USD 80,000), plus warning or suspension of the database.
Zimbabwe CDPA	1	Fines up to level 11 (reported at about USD 1,000) and/or up to 7 years' imprisonment.
UAE (federal) PDPL	0	No fines in force; Cabinet decision defining violations and penalties not issued.