A Comparative Analysis of the UN Cybercrime Treaty and GDPR: Balancing Global Security and Data Sovereignty

This paper presents a comprehensive comparative analysis of the United Nations Convention against Cybercrime (UNCC) and the General Data Protection Regulation (GDPR), focusing on the challenges of balancing global security needs with data sovereignty principles. Through an examination of key provisions and implementation challenges, this study highlights the tensions between the two frameworks. The research compares seven critical factors: jurisdictional scope, data access and transfer mechanisms, data retention policies, encryption and data protection, user rights, incident reporting, and international cooperation. Findings show conflicts between the two frameworks, particularly in cross-border data access and user rights, while identifying potential synergies in international cooperation. This analysis contributes to the ongoing dialogue on developing effective global cybersecurity governance that respects individual privacy rights and national data sovereignty.