Data Analytics and Governance for Business Decision -Assistant Professor Dr. Nattapong Kongprasert
Global Data Privacy Regulations: A Manager's Comparison
Feature GDPR (General Data Protection Regulation)
CCPA/CPRA (California Consumer
Privacy Act/Privacy Rights Act)
PIPL (Personal Information
Protection Law)
PDPA (Personal Data Protection Act)
Region
European Union (EU) & European Economic
Area (EEA)
California, USA People's Republic of China Thailand
Who is Protected?
Anyone in the EU/EEA, regardless of their
citizenship. Has broad extra-territorial reach.
"Consumers" who are residents of
California.
Individuals within the territory of
China. Has extra-territorial reach.
Anyone whose data is collected or
processed in Thailand.
Core Philosophy
Opt-in:Data processing is prohibited by
default. You must have a specific, lawful basis
(like explicit consent) to collect and use data.
Opt-out:Companies can collect and
process data by default, but
consumers must be given an easy
way to opt out of their data being
"sold" or "shared."
Strict Opt- in:Similar to GDPR, but
requires separate, explicit consent
for many different processing
activities (e.g., collecting sensitive
data, transferring data abroad).
Opt-in:Modeled after GDPR. You
must have a lawful basis, and
consent must be explicit, clear, and
easily withdrawn.
Key Right for Individuals
The "Right to be Forgotten" (Right to Erasure),
allowing individuals to request the complete
deletion of their data.
The "Right to Opt- Out of
Sale/Sharing," allowing consumers to
stop businesses from selling their personal information.
Strict control over consent. The ability to withdraw consent easily, and the requirement for re-consent
for new purposes.
The right to access, correct, and request deletion of personal data, similar to GDPR.
Rules on Cross- Border
Data Transfer
Highly Restricted.Data can only be transferred
to countries with an "adequacy decision" from the EU, or via strict legal mechanisms.
Less Restricted.Focuses more on
informing consumers about data transfers than on actively restricting them.
Extremely Restricted.Transferring
data outside of China is a major compliance hurdle, often requiring government security assessments or standard contracts.
Restricted.Similar to GDPR, data
transfers are generally only permitted to countries with adequate data protection standards.
Potential Fines
Up to €20 million or 4%of global annual
revenue, whichever is higher.
Up to $7,500 per intentional violation. Statutory damages in case of data breaches.
Up to RMB 50 million or 5%of the
previous year's annual revenue. Potentially the strictest penalties.
Administrative fines up to THB 5
million, plus potential criminal
penalties and civil damages paid to
individuals.
Key Takeaway for
Managers
The Global Gold Standard.If you have
customers in Europe, you must comply. Its
principles are the foundation for many other
laws.
The U.S. Trendsetter.Focuses on
transparency and giving consumers
control to stop data sales. Signals the
direction of U.S. privacy law.
A Major Operational Hurdle.If you
do business in China, you must prioritize PIPL. The rules on consent and data transfers out of China are extremely challenging.
Your Local Reality.This is Thailand's
GDPR. If you operate here—
especially in tourism, hospitality, or e-commerce—compliance is not
optional. You must understand consent and data rights.