Правове регулювання захисту персональних даних: GDPR та законодавство США, Канади й України

The article provides a detailed analysis of the legal regulation of personal data protection in various jurisdictions, including the European Union, the United States, Canada, and Ukraine. Special attention is given to the General Data Protection Regulation (GDPR), which is one of the strictest international standards in this field. The main provisions of the GDPR are examined, such as the principles of lawfulness, fairness, transparency, purpose limitation, and data minimization, as well as the rights of data subjects, including the right to access, rectification, and erasure of data. The impact of GDPR on international businesses is analyzed, showing how it has forced companies worldwide to adapt their data processing systems to comply with European legal requirements. The section on the United States focuses on California state law, particularly the California Consumer Privacy Act (CCPA), which grants citizens rights over their personal data. Although the U.S. legislative framework is fragmented compared to GDPR, the CCPA is a significant step toward protecting the privacy of American citizens. Canadian legislation is represented by the Personal Information Protection and Electronic Documents Act (PIPEDA), which ensures the protection of personal data in commercial relationships. PIPEDA strikes a balance between business interests and citizens’ rights, providing flexibility in the use of personal data while adhering to principles of transparency and consent. The article also analyzes the process of harmonizing Ukraine’s legislation with the GDPR, which is a crucial step in the context of the country’s integration into the European legal space. Ukrainian legal reforms focus on strengthening citizens’ rights and improving mechanisms for controlling personal data processing. The article offers a comparative analysis of the discussed legal systems, highlighting key differences in data protection approaches. Unlike the EU, where regulation is comprehensive and stringent, U.S. laws are fragmented. In Canada, PIPEDA creates a more flexible system oriented toward the commercial sector. Ukraine, meanwhile, is on its way to full harmonization with European standards, which will enhance the legal protection of citizens in the digital economy.