Consumer Personal Information Protection from a Comparative Law Perspective

In the context of the digital economy, the protection of consumer personal information has increasingly become a common issue faced by laws in various countries. From a comparative law perspective, EU countries have stricter regulations on the protection of consumer personal information, focusing on the overall regulation of how businesses handle personal information. The U.S. law adheres to a typological legislative model, classifying regulation based on the types of risks associated with personal information. China's personal information protection focuses on practical legislation based on the country's circumstances. This paper uses the method of comparative law analysis to examine the legislative and judicial status of personal information protection in two major legal systems and analyze the underlying legal cultural reasons. Regarding the protection of consumer personal information in China, the article identifies issues such as overly simplistic legislation and inconsistency among laws, and proposes corresponding legal improvement suggestions. It emphasizes the need for both public and private law principles, correcting the current over-reliance on civil law protection, and strengthening administrative intervention to play a preemptive role in the review of standard contracts.