GDPR and Bangladesh's data privacy laws: a comprehensive analysis

This article aims to conduct a comparative analysis of data privacy policies, specifically examining the European Union General Data Protection Regulation (GDPR) and Bangladesh's minimalistic legal framework, to assess their impact on data protection and privacy rights. The authors applied the functional method of comparative law to examine how the legal systems of the European Union and Bangladesh address the issues relating to data privacy and compare the outcomes achieved by each legal system. By examining the legal frameworks, principles, and practices, the article provides insights into how these distinct legal systems tackle data protection challenges and highlights potential differences in outcomes. Findings suggest that Bangladesh's data privacy legal regime shares several common principles with the GDPR. However, the primary issue stems from the absence of data subjects' ownership recognition under the Bangladeshi legal regime, rendering it less comprehensive in scope and fewer rights and protections to data subjects.