A Comparative Analysisof Data Protection Laws in India, UK, and the USA. From Consent to Compliance

This paper compares data protection laws in India, the UK, and the USA, focusing on the transition from consent to compliance. It examines how each country defines consent, enforces compliance, and manages cross-border data transfers. While India’s 2023 law emphasizes explicit consent and accountability, the UK follows GDPR-based strict standards, and the USA adopts a fragmented, sectoral approach. The study highlights key differences and common goals in safeguarding personal data in a global digital environment.