PPL

In PPL

• Section 3Definitions
• Section 7Definitions
• Section 9Application for registration
• Section 17CDefinitions
• Section 17GApplication to items of knowledge
• Section 17HNon-application to public bodies
• Section 19Exemption
• Section 23Definitions
• Section 23AApplication to information
• Section 24Application to the State
• Section 27Application of provisions of the Defamation Law
• Section 37Commencement

Reach abroad across 39 laws

Israel PPL	1	No express extraterritorial clause; the PPA applies the law where processing has a material impact on Israelis, e.g. targeting the Israeli market or local servers.
Brazil LGPD	3	Applies regardless of location if processing occurs in Brazil, targets goods or services to people in Brazil, or data was collected in Brazil.
Egypt PDPL	3	Covers Egyptians anywhere, non-Egyptians in Egypt, and non-Egyptians abroad where the data concerns Egyptians or residents and the act is also criminal there.
Ghana DPA	3	Applies to controllers in Ghana, foreign controllers using equipment or processors in Ghana, and processing of information originating in Ghana.
Indonesia PDP Law	3	Applies inside Indonesia and to acts abroad with legal effect in Indonesia or on Indonesian citizens abroad.
Kenya DPA	3	Applies to controllers and processors outside Kenya that process personal data of data subjects located in Kenya.
Nigeria NDPA	3	Applies to controllers and processors outside Nigeria processing personal data of data subjects in Nigeria.
Saudi Arabia PDPL	3	Applies to processing in the Kingdom and to processing outside it of personal data of individuals residing in the Kingdom, by any means.
Switzerland nFADP	3	Applies to any circumstances that have an effect in Switzerland, even if initiated abroad; some foreign controllers must appoint a Swiss representative.
UAE (federal) PDPL	3	Applies to controllers and processors outside the UAE that process personal data of data subjects inside the State.
Uganda DPPA	3	Applies to anyone collecting or processing personal data in Uganda, and to anyone outside Uganda handling data relating to Ugandan citizens.
Vietnam PDPL	3	Applies to foreign entities in Vietnam and to foreign entities directly processing data of Vietnamese citizens and residents in Vietnam.
Australia Privacy Act	2	Applies to organizations abroad with an Australian link, including carrying on business in Australia.
California CCPA	2	Applies to for-profit businesses doing business in California that meet revenue or data-volume thresholds, wherever located, for California residents' data.
Canada PIPEDA	2	Applies to commercial activity with a real and substantial connection to Canada, and to interprovincial or international disclosures for consideration.
China PIPL	2	Applies outside China when providing products or services to people in China or analyzing their behavior; foreign handlers need a local representative.
Ecuador LOPDP	2	Applies to foreign controllers offering goods or services to, or monitoring behavior of, residents of Ecuador; non-residents must appoint an agent in Ecuador.
European Union GDPR	2	Applies to non-EU controllers offering goods or services to, or monitoring the behavior of, people in the EU.
India DPDP Act	2	Applies to processing outside India connected with offering goods or services to data principals in India.
Japan APPI	2	Applies to foreign businesses handling personal information of people in Japan in connection with supplying goods or services to them.
New Zealand Privacy Act	2	Applies to overseas agencies carrying on business in New Zealand, even without a place of business or commercial purpose.
Peru Law 29733	2	Covers non-established controllers that offer goods or services to, or profile, people in Peru; they must appoint a representative.
Philippines DPA	2	Applies to processing outside the Philippines of citizens' or residents' data where the entity has a Philippine link (contract, branch, business, data collected there).
Quebec Law 25	2	Applies to enterprises collecting, holding, using or communicating personal information about people in Quebec in the course of business.
Singapore PDPA	2	Applies to organizations whether or not resident or with an office in Singapore, in practice when collecting, using or disclosing data in Singapore.
South Korea PIPA	2	No express territorial clause, but foreign controllers meeting Decree thresholds without a Korean address must designate a domestic agent; PIPC applies the Act to services targeting Koreans.
Thailand PDPA	2	Applies to controllers or processors abroad that offer goods or services to people in Thailand or monitor their behavior in Thailand.
Turkey KVKK	2	The law is silent on territory, but the Board requires foreign controllers processing data of people in Turkey to register in VERBIS through a local representative.
United Kingdom UK GDPR	2	Applies to non-UK controllers offering goods or services to, or monitoring behavior of, people in the UK.
Uruguay Law 18,331	2	Applies to non-established controllers offering goods or services to, or analyzing behavior of, people in Uruguay, or using means located there.
Colombia Law 1581	1	Applies to processing in Colombia and to foreign controllers or processors when Colombian law applies under international norms or treaties.
DIFC DIFC DPL	1	Applies to controllers or processors incorporated in DIFC, and to processing in DIFC including through stable arrangements, wherever the controller sits.
Hong Kong PDPO	1	Applies to data users controlling data in or from Hong Kong; no express reach over foreign businesses targeting Hong Kong residents.
Malaysia PDPA	1	Applies to persons established in Malaysia, or using equipment in Malaysia other than for transit; foreign users must nominate a local representative.
Mexico LFPDPPP	1	Law applies nationwide; the Regulation also reaches non-established controllers that use means located in Mexico (other than transit).
South Africa POPIA	1	Applies to responsible parties domiciled in South Africa, or not domiciled but using automated or non-automated means in the Republic.
Zimbabwe CDPA	1	Applies to controllers active in Zimbabwe and to controllers not established there that use means located in Zimbabwe.
Argentina Law 25,326	0	No extraterritorial provision; applies to files and databases, public or private, in Argentina.
Chile Law 19,628	0	No extraterritorial provision in the current text.

In PPL

• Section 6De minimis

We don't score this topic in the comparison. The sections on the left are the place to start.

In PPL

• Section 1Prohibition on infringement of privacy

  Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.

• Section 3Definitions

  Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.

• Section 8Registration and use of database

  Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.

Lawful basis across 39 laws

Israel PPL	3	Informed consent is the main basis; the alternative is statutory authority. There is no legitimate-interests basis, and new purposes need new consent.
Argentina Law 25,326	3	Processing is unlawful without consent, except listed cases such as public sources, state functions, basic listings, contracts and certain financial operations. No legitimate interests.
Canada PIPEDA	3	Consent is the default basis, with limited statutory exceptions.
Chile Law 19,628	3	Processing only when a law authorizes it or the holder expressly consents; narrow exceptions for public-source and certain internal data. No legitimate interests.
Colombia Law 1581	3	Prior, express and informed authorization is required, with narrow exceptions (public authority requests, public data, medical emergencies, civil registry). No legitimate interests.
Egypt PDPL	3	Explicit consent is the default; other grounds are contract, legal obligation and exercising legal rights. No legitimate interests ground.
India DPDP Act	3	Consent is the default basis; processing without consent only for listed 'legitimate uses' (s.7). No general legitimate interests ground.
Malaysia PDPA	3	Consent is the general rule; non-consent processing only where necessary for contract, legal obligation, vital interests, justice and similar listed grounds.
Mexico LFPDPPP	3	Consent is the default basis; processing without consent only under listed exceptions (law, public sources, legal relationship, emergency, health care, court order). No legitimate interests.
Peru Law 29733	3	Consent is the default basis; exceptions listed in the Law (public entities, public sources, contracts, health, anonymized data). No legitimate interests.
Quebec Law 25	3	Consent is the default basis for use and communication, with listed exceptions.
UAE (federal) PDPL	3	Processing without consent is prohibited except in listed cases (public interest, contract, legal obligation, public data and others); no legitimate interests ground.
Uganda DPPA	3	Prior consent is the default; exceptions cover law, national security, medical purposes, legal obligation and contracts. No legitimate interests ground.
Uruguay Law 18,331	3	Consent is the default basis, with exceptions for public sources, state functions, limited listings, contracts and domestic use. No legitimate interests.
Vietnam PDPL	3	Consent is the default basis; the Law adds listed exceptions such as contract performance, legal obligations and protecting legitimate rights.
China PIPL	2	Consent or six other bases (contract/HR, legal duty, emergencies, news, public data, other laws); no legitimate interests.
Australia Privacy Act	1	No lawful-basis list; collection must be reasonably necessary, and secondary use needs consent, reasonable expectation or an exception.
Brazil LGPD	1	Ten legal bases including consent, legal obligation, contract, credit protection and legitimate interests.
DIFC DIFC DPL	1	Multiple bases including consent, contract, legal obligation, vital interests and legitimate interests.
Ecuador LOPDP	1	Eight bases including consent, legal obligation, contract, vital interests, public interest and legitimate interest.
European Union GDPR	1	Six lawful bases, including consent, contract, legal obligation, vital interests, public task and legitimate interests.
Ghana DPA	1	Prior consent or listed grounds, including contract, legal obligation, and legitimate interests of the controller or a third party.
Hong Kong PDPO	1	No lawful-basis list; collection must be lawful, fair and for a purpose directly related to the data user's functions.
Indonesia PDP Law	1	Consent, contract, legal obligation, vital interests, public interest/authority, and legitimate interests.
Japan APPI	1	No list of lawful bases; purpose must be specified and notified, and consent is needed for use beyond purpose and for most third-party provision.
Kenya DPA	1	Consent or listed necessity grounds, including legitimate interests unless unwarranted given harm to the data subject.
New Zealand Privacy Act	1	No lawful-basis list; collection must be for a lawful purpose connected to the agency's functions and necessary for it.
Nigeria NDPA	1	Consent or listed necessity grounds, including legitimate interests unless the data subject would not reasonably expect the processing.
Philippines DPA	1	Multiple bases: consent, contract, legal obligation, vital interests, public order, public authority and legitimate interests.
Saudi Arabia PDPL	1	Consent plus other bases, including legitimate interests (since 2023 amendment) after a documented assessment; not for sensitive data.
Singapore PDPA	1	Consent, deemed consent, or exceptions in the First and Second Schedules, including a legitimate interests exception.
South Africa POPIA	1	Six lawful grounds including consent, contract, legal obligation, and legitimate interests of the responsible party or a third party.
South Korea PIPA	1	Consent, law, public duties, contract, vital interests, legitimate interests that clearly override data subject rights, and urgent public safety.
Switzerland nFADP	1	No closed list of bases; processing must follow the principles, and breaches are justified by consent, an overriding private or public interest, or law.
Thailand PDPA	1	Consent or six other bases: research, vital interests, contract, public task, legitimate interests, and legal obligation.
Turkey KVKK	1	Explicit consent is the default, but processing without consent is allowed on listed grounds, including contract, legal obligation and legitimate interests.
United Kingdom UK GDPR	1	Six GDPR bases plus a new 'recognised legitimate interests' basis (Annex 1) needing no balancing test, in force 5 Feb 2026.
Zimbabwe CDPA	1	Consent or listed grounds including legal obligation, vital interests, public interest and legitimate interests of the controller or third party.
California CCPA	0	No lawful-basis requirement; notice at collection plus purpose limitation, with opt-out of sale/sharing.

In PPL

• Section 3Definitions

  'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban.

• Section 17BSecurity officer

  'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban.

Sensitive data across 39 laws

Israel PPL	1	'Information of special sensitivity' is broadly defined (incl. biometrics, location, financial data). It brings higher security levels, PPA notification above 100,000 people, DPO triggers and higher fines, but no ban.
Egypt PDPL	3	Processing sensitive data requires both written explicit consent and a licence from the Personal Data Protection Center.
Argentina Law 25,326	2	No one can be compelled to provide sensitive data; processing only for general interest authorized by law, or dissociated statistics or science.
Australia Privacy Act	2	Sensitive information may be collected only with consent and where reasonably necessary, or under listed exceptions.
Brazil LGPD	2	Sensitive data processed only with specific, highlighted consent or under listed exceptions.
Chile Law 19,628	2	Sensitive data cannot be processed unless a law authorizes it, the holder consents, or it is needed to grant health benefits.
China PIPL	2	Sensitive data needs a specific purpose, sufficient necessity, strict safeguards and separate consent.
Colombia Law 1581	2	Processing sensitive data is prohibited except with explicit authorization or listed exceptions; no activity may be conditioned on providing it.
DIFC DIFC DPL	2	Special categories may not be processed unless a listed condition, such as explicit consent, applies.
Ecuador LOPDP	2	Processing sensitive data is prohibited unless a listed exception applies, such as explicit consent.
European Union GDPR	2	Special categories (health, biometrics, religion, etc.) are prohibited unless explicit consent or another listed exception applies.
Ghana DPA	2	Special personal data (health, religion, ethnicity, sexual life and others) is prohibited unless consent or a listed exception applies.
Japan APPI	2	Special care-required information (race, creed, medical history, criminal record, etc.) needs prior consent to acquire and cannot be shared by opt-out.
Kenya DPA	2	Sensitive personal data may be processed only on listed grounds; health data only by or under health professionals.
Malaysia PDPA	2	Health, political, religious, offence and biometric data need explicit consent or a listed exception.
Mexico LFPDPPP	2	Sensitive data needs express written consent (signature, e-signature or other authentication); databases of sensitive data need a legitimate, specific justification.
Nigeria NDPA	2	Sensitive data (genetic, biometric, health, religion, politics, ethnicity, sex life, union membership) needs specific consent or a listed ground.
Peru Law 29733	2	Sensitive data, including biometric, genetic and neural data, requires written consent by signature or equivalent.
Philippines DPA	2	Processing sensitive and privileged information is prohibited except for listed cases such as specific consent, legal authorization or medical emergencies.
Saudi Arabia PDPL	2	Sensitive data needs explicit consent or a listed basis; legitimate interests cannot be used; DPIA and DPO triggers apply.
South Africa POPIA	2	Special personal information is prohibited unless consent or a listed exception applies; the Regulator may authorize processing in the public interest.
South Korea PIPA	2	Sensitive data (beliefs, union, politics, health, sex life, etc.) may be processed only with separate consent or where law requires or permits.
Switzerland nFADP	2	Sensitive data (incl. genetic, biometric, social assistance, criminal proceedings) needs express consent if relying on consent; disclosing it to third parties needs justification.
Thailand PDPA	2	Sensitive data (health, beliefs, criminal records, biometrics, genetics, etc.) requires explicit consent unless a listed exception applies.
Turkey KVKK	2	Processing special categories, including appearance, clothing and association membership, is prohibited unless an Art. 6(3) exception applies, such as explicit consent, law or employment obligations. Board-set measures are required.
Uganda DPPA	2	Special personal data (beliefs, politics, sexual life, financial, health) may be processed only under listed exceptions, such as freely given consent.
United Kingdom UK GDPR	2	Special categories prohibited unless explicit consent or listed condition applies; many conditions need an appropriate policy document.
Uruguay Law 18,331	2	No one may be compelled to provide sensitive data; processing needs express written consent or legal authorization for general interest.
Vietnam PDPL	2	Sensitive data list set by Government (now includes banking, credit, location and behavioral data); extra safeguards and notice required.
Zimbabwe CDPA	2	Sensitive, genetic, biometric and health data require written consent or listed exceptions; some uses need Authority authorization.
California CCPA	1	Sensitive personal information defined; consumers may limit its use to listed necessary purposes, with notice required.
Canada PIPEDA	1	No special category; sensitivity drives the form of consent, generally express for sensitive information.
Indonesia PDP Law	1	'Specific' data (health, biometric, genetic, criminal, child, financial) defined; mainly triggers DPIA and DPO duties rather than a ban.
Quebec Law 25	1	Sensitive information requires express consent for secondary uses and communication.
UAE (federal) PDPL	1	Sensitive data is defined; no separate prohibition, but large-volume sensitive processing triggers DPO and DPIA duties.
Hong Kong PDPO	0	No special category of sensitive data.
India DPDP Act	0	No separate sensitive data category; volume and sensitivity only factor into Significant Data Fiduciary designation.
New Zealand Privacy Act	0	No special category in the Act; Biometric Processing Privacy Code 2025 regulates biometrics.
Singapore PDPA	0	No statutory special category; PDPC treats some data as sensitive when assessing security and penalties.

In PPL

• Section 13Right of inspection of information

  Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.

• Section 14Amendment of information

  Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.

• Section 17FDeleting information from a database used for direct mail

  Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.

Rights across 39 laws

Israel PPL	2	Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
Brazil LGPD	3	Confirmation, access, correction, anonymization/blocking/deletion, portability, consent revocation, objection and review of automated decisions.
California CCPA	3	Know/access, delete, correct, portability, opt-out of sale/sharing, limit sensitive data, and ADMT opt-out and access rights.
China PIPL	3	Know and decide, restrict or refuse, access and copy, portability, correction, deletion, explanation and refusal of solely automated decisions.
DIFC DIFC DPL	3	Withdraw consent, access, rectification, erasure, objection (incl. direct marketing), restriction, portability and automated-decision rights.
Ecuador LOPDP	3	Information, access, rectification, deletion, objection, portability, suspension of processing, and not to be subject to solely automated decisions.
European Union GDPR	3	Access, rectification, erasure, restriction, portability, objection and rights on solely automated decisions.
Indonesia PDP Law	3	Information, correction, access, erasure, withdrawal, objection to automated decisions, restriction/suspension, portability and compensation.
Kenya DPA	3	Information, access, objection, correction, deletion, restriction, portability, and the right not to be subject to solely automated decisions.
Nigeria NDPA	3	Access, copy, rectification, erasure, restriction, portability, objection (absolute for direct marketing) and safeguards against solely automated decisions.
Peru Law 29733	3	Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).
Quebec Law 25	3	Access, rectification, portability, de-indexing or cessation of dissemination, consent withdrawal, and information on automated decisions.
South Africa POPIA	3	Access, correction, deletion, objection (including direct marketing), protection from solely automated decisions, and restriction in limited cases.
South Korea PIPA	3	Access, portability (transmission), correction, erasure, suspension of processing, and the right to object to or seek explanation of automated decisions.
Switzerland nFADP	3	Access, rectification, deletion, restriction/prohibition of processing, objection, data portability, and a right to be heard on automated individual decisions.
Thailand PDPA	3	Access, portability, objection, erasure, restriction and rectification.
UAE (federal) PDPL	3	Information and access, portability, correction and erasure, restriction, objection (incl. direct marketing) and rights against automated decisions.
United Kingdom UK GDPR	3	Access, rectification, erasure, restriction, portability, objection, and safeguards on significant automated decisions, plus a right to complain to the controller.
Argentina Law 25,326	2	Access, rectification, updating and suppression; removal or blocking of marketing data at any time.
Chile Law 19,628	2	Information (access), modification, deletion and blocking; opposition to use for advertising, market research or surveys.
Colombia Law 1581	2	Know, update and correct data; proof of authorization; information on use; complain to SIC; revoke authorization or request deletion.
Egypt PDPL	2	Know and access data, withdraw consent, correct and erase, restrict processing, object, and be told of breaches.
Ghana DPA	2	Access, correction and deletion, the right to prevent processing, direct marketing opt-out, and rights against solely automated decisions.
Japan APPI	2	Disclosure (access), correction/deletion, cessation of use or erasure, cessation of third-party provision, and disclosure of third-party provision records.
Malaysia PDPA	2	Access, correction, withdrawal of consent, prevent damaging processing, stop direct marketing and data portability.
Mexico LFPDPPP	2	ARCO rights: access, rectification, cancellation and opposition, including objection to automated processing with significant effects. No portability right.
Philippines DPA	2	Right to be informed, access, rectification, erasure or blocking, objection (incl. direct marketing), portability and damages.
Saudi Arabia PDPL	2	Rights to be informed, access and copy, correction, restriction and destruction; no portability right.
Turkey KVKK	2	Learn whether data is processed and get information (access), rectification, erasure, notice to third-party recipients, objection to solely automated outcomes, and compensation.
Uganda DPPA	2	Access, correction and deletion, objection to damaging processing, direct marketing opt-out, and rights against solely automated decisions.
Uruguay Law 18,331	2	Access, rectification, updating, inclusion, suppression; challenge automated decisions; removal or blocking of marketing data.
Vietnam PDPL	2	Be informed, consent and withdraw, access, correction, deletion, restriction, objection, complaint and lawsuit.
Zimbabwe CDPA	2	Information, access, objection, correction and deletion of false data, and protection from solely automated decisions.
Australia Privacy Act	1	Access and correction; no statutory erasure, portability or objection rights (direct marketing opt-out aside).
Canada PIPEDA	1	Access, correction, and withdrawal of consent; no statutory deletion, portability or automated-decision rights.
Hong Kong PDPO	1	Access and correction only.
India DPDP Act	1	Access to information, correction, completion, updating and erasure, grievance redressal and nomination. No portability, objection or automated-decision rights.
New Zealand Privacy Act	1	Access and correction only.
Singapore PDPA	1	Access and correction; data portability enacted but not yet in force; right to withdraw consent.

In PPL

• Section 17FDeleting information from a database used for direct mail

  Prior written or electronic opt-in for commercial electronic messages, with a narrow existing-customer exception; the PPL also gives an absolute right to opt out of direct mail.

Marketing across 39 laws

Israel PPL	2	Prior written or electronic opt-in for commercial electronic messages, with a narrow existing-customer exception; the PPL also gives an absolute right to opt out of direct mail.
Colombia Law 1581	3	Any marketing use needs prior, express, informed authorization for that purpose; holders may revoke at any time.
Ghana DPA	3	Direct marketing requires the data subject's prior written consent, and data subjects may later require it to stop.
Hong Kong PDPO	3	Consent (incl. 'no objection') required before using or providing personal data for any direct marketing; oral consent confirmed in writing within 14 days.
Kenya DPA	3	Commercial use, including direct marketing, requires express consent; messages must carry a simple opt-out, and objection is absolute.
Nigeria NDPA	3	Consent is required for any direct marketing; objection to direct marketing is absolute.
Peru Law 29733	3	Consent for marketing must be obtained directly; one first contact allowed to seek it, no further contact if refused; opt-outs handled within 10 days.
Saudi Arabia PDPL	3	Consent required before sending advertising or using personal data for direct marketing; easy opt-out required; no existing-customer exception confirmed.
Australia Privacy Act	2	APP 7 requires opt-out; Spam Act 2003 requires opt-in consent for commercial electronic messages.
China PIPL	2	Automated-decision marketing must offer a non-personalized option or easy refusal; marketing otherwise needs consent.
Egypt PDPL	2	Electronic direct marketing requires prior consent, a clear opt-out and a Center licence; consent records kept three years.
European Union GDPR	2	Absolute right to object to direct marketing; prior consent required for electronic marketing under the ePrivacy Directive, with a customer soft opt-in.
Japan APPI	2	Marketing email requires prior opt-in consent under the Act on Regulation of Transmission of Specified Electronic Mail.
New Zealand Privacy Act	2	Commercial electronic messages require consent under the Unsolicited Electronic Messages Act 2007.
South Africa POPIA	2	Electronic direct marketing requires prior opt-in consent, which may be requested only once; existing customers may receive similar offers with an opt-out.
South Korea PIPA	2	Electronic advertising requires the recipient's prior explicit opt-in consent.
Switzerland nFADP	2	Opt-in for automated mass advertising (email, SMS), except to existing customers for similar products with an opt-out offered.
Turkey KVKK	2	Commercial electronic messages need prior opt-in consent recorded in the national IYS system; opt-outs must be honored within 3 business days.
United Kingdom UK GDPR	2	Prior consent needed for electronic marketing, with soft opt-in for existing customers (extended to charities by DUAA); absolute right to object.
Vietnam PDPL	2	Consent required for behavioral and targeted advertising, with an opt-out mechanism, plus anti-spam rules.
Argentina Law 25,326	1	Marketing may use data from public sources or provided by the holder; holders may demand removal or blocking at any time (opt-out).
Brazil LGPD	1	No specific marketing rule; requires a legal basis, and data subjects may object or revoke consent.
California CCPA	1	Right to opt out of selling or sharing data for cross-context behavioral advertising; email marketing governed by federal CAN-SPAM.
Canada PIPEDA	1	Opt-out consent can suffice for non-sensitive secondary marketing uses; commercial electronic messages need opt-in under CASL.
Chile Law 19,628	1	Holders may object to use of their data for advertising, market research or opinion surveys (opt-out).
DIFC DIFC DPL	1	Inform subjects before first disclosure for marketing and honor the right to object at any time, offered by the first communication.
Ecuador LOPDP	1	Data subjects may object at any time to direct marketing, including related profiling.
Malaysia PDPA	1	Data subjects may require a controller, by written notice, to stop or not begin processing for direct marketing.
Mexico LFPDPPP	1	Marketing is a secondary purpose disclosed in the privacy notice; data subjects can object or opt out.
Philippines DPA	1	Data subjects have a right to object to direct marketing; processing must stop on objection.
Quebec Law 25	1	Prospection must identify the enterprise and inform individuals of their right to withdraw consent; electronic messages need CASL opt-in.
Singapore PDPA	1	Check the Do Not Call Register before marketing calls or texts unless clear consent; marketing use of data also needs consent.
Thailand PDPA	1	Data subjects may object to direct marketing at any time; no PDPA-specific opt-in for electronic marketing.
UAE (federal) PDPL	1	Data subjects may object to processing for direct marketing, including related profiling.
Uganda DPPA	1	Data subjects may require a controller to stop direct marketing processing; the controller must respond within 14 days.
Uruguay Law 18,331	1	Marketing profiles only from public sources, data provided by the holder or with consent; holder may request removal or blocking at any time.
Zimbabwe CDPA	1	Data subjects may object free of charge to processing for direct marketing; no opt-in rule.
India DPDP Act	0	No specific direct marketing rule; marketing requires consent like other processing; targeted ads to children banned.
Indonesia PDP Law	0	Not addressed specifically; marketing needs a lawful basis and consent can be withdrawn.

In PPL

• Section 17BSecurity officer

  Required for public bodies, data brokers and direct mailers above 10,000 people, and entities whose core activity is systematic monitoring or large-scale special-sensitivity data.

DPO required across 39 laws

Israel PPL	1	Required for public bodies, data brokers and direct mailers above 10,000 people, and entities whose core activity is systematic monitoring or large-scale special-sensitivity data.
Canada PIPEDA	3	Every organization must designate an individual accountable for compliance.
Colombia Law 1581	3	Every controller and processor must designate a person or area to assume the data protection function and handle requests.
Egypt PDPL	3	Every legal-entity controller and processor must appoint a qualified employee as DPO and register them with the Center.
Mexico LFPDPPP	3	Every controller must designate a person or data protection department to handle ARCO requests and promote data protection internally.
New Zealand Privacy Act	3	Every agency must appoint one or more privacy officers.
Philippines DPA	3	Every personal information controller and processor must designate a DPO or accountable individual, and register one DPO.
Quebec Law 25	3	The person with highest authority in every enterprise is by default the person in charge of personal information protection; may delegate in writing.
Singapore PDPA	3	Every organization must designate one or more individuals responsible for PDPA compliance and publish business contact information.
South Africa POPIA	3	Every public and private body has an Information Officer (the head by default), who must be registered with the Regulator before taking up duties.
South Korea PIPA	3	Every controller must designate a chief privacy officer; small businesses default to the owner or representative.
Uganda DPPA	3	The head of every institution covered by the Act must designate a data protection officer.
Zimbabwe CDPA	3	Every data controller must appoint a DPO and notify POTRAZ on Form DP2.
Brazil LGPD	2	Controllers must appoint an encarregado; ANPD may exempt small processing agents.
Ghana DPA	2	Statute lets controllers appoint a certified data protection supervisor; DPC guidance requires medium and large controllers to appoint one.
Nigeria NDPA	2	Data controllers and processors of major importance must designate a DPO; low thresholds (over 200 data subjects in six months) capture many firms.
Vietnam PDPL	2	Must appoint qualified data protection personnel or department, or hire a service provider.
Australia Privacy Act	1	Not required for organizations; Australian Government agencies must appoint a privacy officer under the Agencies Code.
China PIPL	1	Handlers processing personal information above the volume set by the CAC must appoint a personal information protection officer.
DIFC DIFC DPL	1	DPO required for DIFC Bodies and for controllers or processors performing high-risk processing on a systematic or regular basis.
Ecuador LOPDP	1	DPO required for public-sector processing, large-scale systematic monitoring and large-scale processing of special categories.
European Union GDPR	1	DPO required for public bodies, large-scale systematic monitoring, or large-scale special-category or criminal data processing.
India DPDP Act	1	Only Significant Data Fiduciaries notified by the government must appoint a DPO; others publish contact of a DPO or responsible person.
Indonesia PDP Law	1	DPO required for public-service processing, large-scale systematic monitoring, or large-scale specific/criminal data; any one trigger suffices.
Kenya DPA	1	Controllers and processors may appoint a DPO for public or private bodies, systematic monitoring, or sensitive data processing.
Malaysia PDPA	1	Controllers and processors must appoint a DPO when processing data of over 20,000 subjects, sensitive data of over 10,000, or systematic monitoring.
Peru Law 29733	1	Data protection officer required for public entities, large-scale or sensitive processing, and core sensitive-data activities; phased in by company size through Nov 2028.
Saudi Arabia PDPL	1	DPO required for public entities processing at large scale, and where core activities involve systematic monitoring or sensitive data.
Switzerland nFADP	1	Optional for private controllers; federal bodies must appoint a data protection advisor.
Thailand PDPA	1	DPO required for public authorities, large-scale regular monitoring, or core activities involving sensitive data.
UAE (federal) PDPL	1	DPO required for high-risk processing, systematic assessment of sensitive data including profiling, or large-volume sensitive data.
United Kingdom UK GDPR	1	DPO required for public authorities, large-scale systematic monitoring, or large-scale special-category or criminal data processing.
Uruguay Law 18,331	1	DPO required for public bodies, majority state-owned entities, private entities whose core business is sensitive data, and those processing data of over 35,000 people.
California CCPA	0	No DPO requirement; executive accountable for risk-assessment attestations and cybersecurity audit certification.
Hong Kong PDPO	0	No DPO requirement.
Japan APPI	0	No DPO requirement; controllers must take necessary security control measures, including organizational measures.
Turkey KVKK	0	No DPO requirement; registered controllers must appoint a contact person for the Authority and data subjects.
Argentina Law 25,326	–	Not addressed
Chile Law 19,628	–	Not addressed

In PPL

• Section 8Registration and use of database
• Section 9Application for registration
• Section 10Powers of the Registrar
• Section 12Register of databases

Registration across 39 laws

Israel PPL	1	Registration only for public-body databases and databases of 10,000+ people mainly used to transfer data for payment; notify the PPA of special-sensitivity databases above 100,000 people.
Egypt PDPL	3	Controllers and processors need Center licences with fees capped at EGP 2 million, plus permits for transfers, marketing and CCTV.
Ghana DPA	3	Every data controller must register with the Commission, pay a fee and renew every two years; processing unregistered is an offense.
Kenya DPA	3	Controllers and processors must register, pay tiered fees (KES 4,000-40,000) and renew every 24 months; small entities exempt unless in listed sectors.
Uganda DPPA	3	All collectors, processors and controllers must register with the PDPO, renew annually and pay fees (UGX 100,000 reported).
Zimbabwe CDPA	3	Controllers processing data of 50 or more people need a POTRAZ licence, tiered USD 50-2,500, renewed every 12 months.
Argentina Law 25,326	2	Public databases and private databases that go beyond exclusively personal use must register with the AAIP registry.
DIFC DIFC DPL	2	Controllers and processors must register by filing a notification of processing with the Commissioner, kept up to date, with fees.
Ecuador LOPDP	2	Controllers must register with and keep updated the National Personal Data Protection Registry.
Malaysia PDPA	2	Prescribed classes of controllers (banking, insurance, health, telecoms, education, real estate and others) must register and renew certificates with fees.
Nigeria NDPA	2	Controllers and processors of major importance must register, with fees of N10,000-250,000 by tier; ordinary-tier entities renew annually.
Peru Law 29733	2	Creation, modification and cancellation of personal data banks must be registered (free, automatic approval) with the National Registry.
Philippines DPA	2	Register processing systems and DPO if 250+ employees, sensitive data of 1,000+ individuals, or risky processing; renew annually.
Turkey KVKK	2	Controllers must register in VERBIS before processing, unless exempt (under 50 employees and under TRY 100m balance sheet, or under 10 and TRY 10m if mainly sensitive data).
United Kingdom UK GDPR	2	Most controllers must pay an annual data protection fee to the ICO unless exempt.
Uruguay Law 18,331	2	All public and private databases, other than purely personal ones, must be registered with the URCDP, including foreign controllers in scope.
California CCPA	1	No general registration; data brokers must register annually with the CPPA under the Delete Act.
Colombia Law 1581	1	Companies and non-profits above an asset threshold (and public entities) must register databases in the SIC's National Database Registry (RNBD) and update annually.
Indonesia PDP Law	1	No PDP Law registration; electronic system operators register with the ministry under GR 71/2019.
Japan APPI	1	No general registration; businesses using the opt-out route for third-party provision must notify the PPC in advance.
Saudi Arabia PDPL	1	National Register of Controllers applies to public entities, controllers whose main activity is processing, sensitive-data processors and some individuals; no fees seen.
South Africa POPIA	1	No general controller registration. Information Officers must be registered; prior authorization needed for listed processing such as credit reporting.
South Korea PIPA	1	Public institutions must register personal information files with the PIPC; no registration for private controllers.
Switzerland nFADP	1	No registration for private controllers; federal bodies must report their processing activities to the FDPIC.
Vietnam PDPL	1	No controller registration; impact assessment dossiers are filed with the Ministry of Public Security instead.
Australia Privacy Act	0	No registration of organizations.
Chile Law 19,628	0	No registration for private controllers; the Civil Registry keeps a registry of public bodies' databases.
China PIPL	0	No general controller registration; foreign handlers report their China representative to regulators.
European Union GDPR	0	No general registration; controllers communicate DPO contact details to the supervisory authority.
Hong Kong PDPO	0	Data user return scheme exists but has not been activated for any class of data user.
India DPDP Act	0	No general controller registration. Only Consent Managers must register with the Data Protection Board.
Mexico LFPDPPP	0	No registration or notification of databases with the regulator.
New Zealand Privacy Act	0	No registration.
Singapore PDPA	0	No controller registration.
Thailand PDPA	0	No registration of controllers.
UAE (federal) PDPL	0	No controller registration or licensing.
Brazil LGPD	–	Not addressed
Canada PIPEDA	–	Not addressed
Quebec Law 25	–	Not addressed

In PPL

• Section 16Confidentiality
• Section 17Responsibility for information security
• Section 17BSecurity officer

We don't score this topic in the comparison. The sections on the left are the place to start.

In PPL

• Section 10Powers of the Registrar

We don't score this topic in the comparison. The sections on the left are the place to start.

In PPL

• Section 4Infringement of privacy: a civil wrong

  Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available.

• Section 13Right of inspection of information
• Section 13AInspection of information not in the possession of the database owner
• Section 15Appeal to the court
• Section 29Additional orders
• Section 29ACompensation without proof of damage

  Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available.

Private action across 39 laws

Israel PPL	3	Civil tort claims plus statutory damages without proof of harm: up to ILS 10,000 for listed database violations, more for privacy infringement. Class actions are available.
Brazil LGPD	3	Controllers and processors must compensate material or moral damage; individual and collective actions allowed.
California CCPA	3	Private right of action for data breaches from failure to maintain reasonable security: USD 107-799 per consumer per incident, class actions allowed.
China PIPL	3	Tort claims with presumed fault of the handler; prosecutors and designated organizations may bring public interest suits.
European Union GDPR	3	Right to compensation for material or non-material damage; representative bodies may bring claims, including collective redress.
Quebec Law 25	3	Courts must award punitive damages of at least CAD 1,000 for intentional or grossly negligent infringements; class actions available.
South Korea PIPA	3	Damages with reversed burden of proof, up to 5x for intentional or negligent leaks, statutory damages up to KRW 3 million, and group suits.
Thailand PDPA	3	Strict liability for damages, plus punitive damages up to twice actual damages; class actions available under civil procedure.
Argentina Law 25,326	2	Habeas data court action to access, rectify, suppress or keep data confidential; liability for damages also arises.
Australia Privacy Act	2	Statutory tort for serious invasions of privacy (from 10 Jun 2025); representative complaints to OAIC.
Chile Law 19,628	2	Controller must compensate material and moral damage from improper processing; amount set by the judge.
Colombia Law 1581	2	Data subjects complain to SIC after exhausting the controller process; damages are claimed under general civil liability.
DIFC DIFC DPL	2	Data subjects may sue directly in DIFC Courts for financial and non-financial harm, including distress.
Ecuador LOPDP	2	Data subjects may sue for damages (Constitution art. 92 habeas data) and must be guaranteed full reparation.
Egypt PDPL	2	Victims keep the right to claim compensation; entities are jointly liable for employees' violations.
Ghana DPA	2	Individuals who suffer damage or distress from a contravention are entitled to compensation, subject to a reasonable care defense.
Hong Kong PDPO	2	Individuals suffering damage, including injury to feelings, may claim compensation; PCPD may give legal assistance.
Indonesia PDP Law	2	Data subjects may sue for compensation for violations of processing.
Japan APPI	2	Individuals may sue to compel disclosure, correction or cessation, and claim tort damages under the Civil Code.
Kenya DPA	2	Persons who suffer damage, including distress, are entitled to compensation from the controller or processor.
Mexico LFPDPPP	2	Administrative sanctions apply without prejudice to civil liability, so data subjects can claim damages in the civil courts.
New Zealand Privacy Act	2	After a Commissioner complaint, individuals may bring proceedings in the Human Rights Review Tribunal for damages.
Nigeria NDPA	2	Data subjects who suffer injury, loss or harm may sue for damages; the Commission can also order compensation.
Peru Law 29733	2	Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action.
Philippines DPA	2	Data subjects may be indemnified for damages from inaccurate or unlawful processing.
Saudi Arabia PDPL	2	Anyone harmed may seek proportionate compensation for material or moral damage before the competent court.
Singapore PDPA	2	Persons suffering loss or damage may sue for injunction, declaration, damages or other relief.
South Africa POPIA	2	Data subjects, or the Regulator on their behalf, may sue for patrimonial, non-patrimonial and aggravated damages, regardless of intent or negligence.
Switzerland nFADP	2	Data subjects can sue for injunctions, rectification or deletion, damages, moral damages and surrender of profits.
Turkey KVKK	2	Data subjects can claim compensation in civil courts for damage from unlawful processing; complaints to the Board come after a request to the controller.
Uganda DPPA	2	A data subject who suffers damage or distress may apply to court for compensation; complaints also go to the PDPO.
United Kingdom UK GDPR	2	Individuals can claim compensation for material or non-material damage; representative actions are limited in practice.
Uruguay Law 18,331	2	Habeas data court action with summary procedure to access, rectify, include or delete data.
Vietnam PDPL	2	Violators must compensate damage; controllers and processors liable for losses caused by their processing.
Canada PIPEDA	1	After a Commissioner complaint, individuals may apply to the Federal Court for damages, including for humiliation.
India DPDP Act	1	Civil courts barred; data principals complain to the Data Protection Board after exhausting grievance redressal. No compensation provision.
UAE (federal) PDPL	1	Data subjects may complain to the Data Office; no compensation or civil claim provision.
Zimbabwe CDPA	1	No statutory compensation right; data subjects complain to POTRAZ, with appeal to the Administrative Court.
Malaysia PDPA	0	No statutory right for data subjects to sue for compensation; complaints go to the Commissioner.

In PPL

• Section 5Infringement of privacy: an offense

  Privacy infringement and breach of confidentiality carry up to 5 years in prison; Amendment 13 added offenses such as obstructing or misleading the PPA (6 months to 3 years).

• Section 16Confidentiality

  Privacy infringement and breach of confidentiality carry up to 5 years in prison; Amendment 13 added offenses such as obstructing or misleading the PPA (6 months to 3 years).

• Section 31APenalties for offenses of due diligence
• Section 34Amendment of the Criminal Procedure Law

Maximum fine across 39 laws

Israel PPL	3	Tiered administrative fines, many per data subject (e.g., ILS 4-8 per person for sensitive databases), plus fixed amounts up to ILS 640,000 per violation; no overall cap stated.
Australia Privacy Act	3	Body corporate: greater of AUD 50 million, 3x the benefit, or 30% of adjusted turnover for serious interferences.
Brazil LGPD	3	Simple fine up to 2% of Brazil revenue for the prior year, capped at BRL 50 million per infraction; daily fines also possible.
China PIPL	3	Up to RMB 50 million or 5% of prior-year revenue; responsible individuals RMB 100,000 to 1 million.
Ecuador LOPDP	3	Serious infringements: 0.7% to 1% of prior-year business volume; public servants 10 to 20 basic salaries.
European Union GDPR	3	Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher.
India DPDP Act	3	Up to INR 250 crore (about USD 30m) per instance for security safeguard failures.
Indonesia PDP Law	3	Administrative fines up to 2% of annual revenue; criminal corporate fines up to 10x individual maximum.
Nigeria NDPA	3	Greater of N10 million or 2% of prior-year annual gross revenue for entities of major importance; N2 million or 2% for others.
Quebec Law 25	3	Penal fines up to CAD 25 million or 4% of worldwide turnover; administrative penalties up to CAD 10 million or 2%.
Singapore PDPA	3	Up to 10% of annual Singapore turnover if over SGD 10 million, otherwise SGD 1 million.
South Korea PIPA	3	Penalty surcharge up to 3% of total revenue (excluding unrelated revenue); up to 10% for repeat, mass (10m+) or post-order breaches.
Uganda DPPA	3	Courts may fine a corporation up to 2% of annual gross turnover; individual offenses up to 245 currency points (UGX 4.9 million).
United Kingdom UK GDPR	3	Up to GBP 17.5 million or 4% of worldwide annual turnover, whichever is higher; PECR fines now aligned to the same level.
Vietnam PDPL	3	Up to 5% of prior-year revenue for cross-border violations, 10x revenue for illegal data trading, VND 3 billion for other violations.
California CCPA	2	Up to USD 2,663 per violation or USD 7,988 per intentional violation or violation involving minors, with no aggregate cap.
Colombia Law 1581	2	Up to 2,000 monthly minimum wages (roughly USD 0.7m), plus suspension or closure of operations.
DIFC DIFC DPL	2	Administrative fines up to USD 100,000 per standard contravention under Schedule 2.
Egypt PDPL	2	Fines up to EGP 5 million (about USD 100,000) per offense, doubled for repeat offenses.
Hong Kong PDPO	2	Criminal fines up to HKD 1,000,000 (about USD 128k) for doxxing causing harm or selling data for marketing.
Japan APPI	2	Criminal corporate fine up to JPY 100 million for violating PPC orders or unlawful database provision. Amendment adds revenue-linked administrative surcharges.
Malaysia PDPA	2	Up to RM1,000,000 (about USD 235k) and/or 3 years' imprisonment for breaching the data protection principles.
Mexico LFPDPPP	2	Up to 320,000 UMA (about MXN 36 million, roughly USD 2m), doubled for sensitive data, plus an additional fine of up to 320,000 UMA for repeat violations.
Peru Law 29733	2	Up to 100 UIT (about PEN 535,000, roughly USD 145,000), not exceeding 10% of prior-year gross income.
Saudi Arabia PDPL	2	Fines up to SAR 5 million (about USD 1.3m) per violation, doubled for repeat violations.
South Africa POPIA	2	Administrative fine up to R10 million (about USD 550,000).
Switzerland nFADP	2	Criminal fine up to CHF 250,000 per individual; a company can be fined up to CHF 50,000 when identifying the individual is disproportionate.
Thailand PDPA	2	Administrative fines up to THB 5 million per violation (about USD 150k).
Turkey KVKK	2	Administrative fines up to TRY 17,092,242 per violation in 2026, revalued each year.
Argentina Law 25,326	1	ARS 1,000 to 100,000 per infringement; total for the same conduct capped at ARS 50 million (about USD 35,000-40,000).
Canada PIPEDA	1	Fines up to CAD 100,000 on indictment (CAD 10,000 summary) for knowing breach-reporting and listed violations; no administrative fines.
Chile Law 19,628	1	Court-imposed fines of 1 to 10 UTM, or 10 to 50 UTM for economic, financial and commercial data (about USD 3,500 at most).
Ghana DPA	1	General penalty up to 5,000 penalty units (about GHS 60,000) and/or 10 years' imprisonment.
Kenya DPA	1	Up to KES 5 million or 1% of prior-year annual turnover, whichever is lower (about USD 39,000 maximum).
New Zealand Privacy Act	1	Criminal fines up to NZD 10,000 (e.g. failing to notify a breach).
Philippines DPA	1	Criminal fines up to PHP 5 million; administrative fines up to 3% of annual gross income, capped at PHP 5 million (about USD 86k) per act.
Uruguay Law 18,331	1	Up to 500,000 indexed units (UI) (roughly USD 80,000), plus warning or suspension of the database.
Zimbabwe CDPA	1	Fines up to level 11 (reported at about USD 1,000) and/or up to 7 years' imprisonment.
UAE (federal) PDPL	0	No fines in force; Cabinet decision defining violations and penalties not issued.