LPDP

In LPDP

• Article 1Purpose of the law
• Article 2Definitions
• Article 3Scope of application
• Article 13Scope of processing of personal data

Reach abroad across 39 laws

Peru Law 29733	2	Covers non-established controllers that offer goods or services to, or profile, people in Peru; they must appoint a representative.
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.
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.
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.
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 LPDP

• Article 4Principle of legality
• Article 5Principle of consent
• Article 6Principle of purpose
• Article 7Principle of proportionality
• Article 8Principle of quality
• Article 9Principle of security
• Article 10Principle of availability of remedies
• Article 11Principle of adequate level of protection
• Article 12Value of the principles

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

In LPDP

• Article 5Principle of consent
• Article 13Scope of processing of personal data

  Consent is the default basis; exceptions listed in the Law (public entities, public sources, contracts, health, anonymized data). No legitimate interests.

• Article 14Limits on consent for processing

  Consent is the default basis; exceptions listed in the Law (public entities, public sources, contracts, health, anonymized data). No legitimate interests.

Lawful basis across 39 laws

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.
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.
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.
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.
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 LPDP

• Article 13Scope of processing of personal data

  Sensitive data, including biometric, genetic and neural data, requires written consent by signature or equivalent.

• DCF-8Sensitive information

Sensitive data across 39 laws

Peru Law 29733	2	Sensitive data, including biometric, genetic and neural data, requires written consent by signature or equivalent.
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.
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.
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.
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 LPDP

• Article 18Right to information

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 19Right of access

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 20Right to updating, inclusion, rectification and deletion

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 21Right to prevent disclosure

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 22Right to object

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 23Right to objective processing

  Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).

• Article 24Right to protection (tutela)
• Article 25Right to compensation

Rights across 39 laws

Peru Law 29733	3	Information, access, portability, rectification, cancellation, opposition, and objective treatment (no solely automated decisions with significant effects).
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.
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.
Israel PPL	2	Access, correction or deletion of inaccurate data, deletion from direct-mail databases (opt-out), and erasure for EEA-origin data.
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 LPDP

• Article 34National Personal Data Protection Register

  Creation, modification and cancellation of personal data banks must be registered (free, automatic approval) with the National Registry.

Registration across 39 laws

Peru Law 29733	2	Creation, modification and cancellation of personal data banks must be registered (free, automatic approval) with the National Registry.
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.
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.
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.
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 LPDP

• Article 9Principle of security
• Article 16Security of processing
• Article 17Confidentiality of personal data
• Article 35Confidentiality
• DCF-2Security directive

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

In LPDP

• Article 15Cross-border flow of personal data

  Transfers allowed to adequate countries or with safeguards such as model clauses; every cross-border flow must be notified to the Authority.

Transfers abroad across 39 laws

Peru Law 29733	2	Transfers allowed to adequate countries or with safeguards such as model clauses; every cross-border flow must be notified to the Authority.
China PIPL	3	Transfers need CAC security assessment, certification or the CAC standard contract, plus notice and separate consent.
Egypt PDPL	3	Transfers abroad need equivalent protection in the destination and a licence or permit from the Center, unless a listed exception applies.
Vietnam PDPL	3	Transfer impact assessment dossier must be filed with MPS within 60 days of first transfer, plus a written agreement with the recipient.
Argentina Law 25,326	2	Transfers prohibited to countries or bodies without adequate protection, except listed cases such as treaties, judicial cooperation and other statutory exceptions.
Brazil LGPD	2	Transfers allowed via adequacy, ANPD standard clauses (mandatory since Aug 2025), ANPD-approved specific clauses or BCRs, or specific consent.
Colombia Law 1581	2	Transfers to countries without adequate protection are prohibited unless an exception applies (explicit consent, contract, treaty) or SIC issues a declaration of conformity.
DIFC DIFC DPL	2	Transfer if destination has adequate protection or with appropriate safeguards, or listed derogations.
Ecuador LOPDP	2	Transfers allowed to countries declared adequate by the regulator, or with binding guarantees or binding corporate rules; listed exceptions include explicit consent.
European Union GDPR	2	Transfers outside the EEA need an adequacy decision or appropriate safeguards (SCCs, BCRs), or a listed derogation.
Indonesia PDP Law	2	Destination must offer equal or higher protection, else adequate binding safeguards, else consent; BCRs need DPA approval under GR 33.
Israel PPL	2	Allowed only if the destination's protection is no lower than Israel's, or under listed exceptions such as consent, EU-adequate or Convention 108 countries, group or contractual safeguards; no PPA approval.
Japan APPI	2	Transfer abroad needs prior consent after information on the destination regime, an adequate country (EU/UK), or a recipient with equivalent systems.
Kenya DPA	2	Transfers need proof of appropriate safeguards to the Data Commissioner or a listed condition; sensitive data needs consent.
Malaysia PDPA	2	Transfer allowed if destination law is substantially similar or protection equivalent, or under listed exceptions (consent, contract, due diligence).
Mexico LFPDPPP	2	Domestic and international transfers need consent via the privacy notice, with listed exceptions; recipient assumes the controller's obligations, typically by contract.
New Zealand Privacy Act	2	Overseas disclosure allowed only with comparable safeguards, consent after warning, prescribed binding scheme or country, or contract.
Nigeria NDPA	2	Transfers need an adequate level of protection in the destination or a listed basis such as informed consent.
Quebec Law 25	2	Before communicating data outside Quebec, conduct a PIA confirming adequate protection and sign a written agreement.
Saudi Arabia PDPL	2	Transfers need a specified purpose, minimum data, and adequacy, BCRs, standard clauses, certification or listed derogations, with a risk assessment.
Singapore PDPA	2	Transfers only under prescribed requirements ensuring a comparable standard of protection (contracts, BCRs, certification, consent).
South Africa POPIA	2	Transfers abroad allowed only with adequate protection (law, binding corporate rules or agreement), consent, contract necessity, or data subject benefit.
South Korea PIPA	2	Transfer abroad needs separate consent, a statutory basis, contract necessity with disclosure, a certified recipient, or a PIPC-recognized country.
Switzerland nFADP	2	Allowed to Federal Council-listed adequate countries; otherwise FDPIC-recognized SCCs, FDPIC-approved BCRs, or notified clauses; limited derogations such as explicit consent.
Thailand PDPA	2	Destination must have adequate standards, or a listed exception applies (consent, contract, etc.); intra-group transfers need a PDPC-certified policy.
Turkey KVKK	2	Needs a Board adequacy decision; else Board-approved BCRs or undertakings, or a Board standard contract filed within five business days. Incidental transfers allowed on listed grounds.
UAE (federal) PDPL	2	Transfer to countries with adequate protection approved by the Data Office, or via contract, explicit consent and other listed grounds.
Uganda DPPA	2	Processing or storage abroad requires adequate protection at least equivalent to the Act, or data subject consent; onward transfer needs express consent.
United Kingdom UK GDPR	2	Transfers need UK adequacy regulations under a 'not materially lower' data protection test, or appropriate safeguards such as the IDTA or Addendum.
Uruguay Law 18,331	2	Transfers prohibited to countries without adequate protection, except listed cases (explicit consent, contract, vital interest); URCDP may authorize transfers with safeguards.
Zimbabwe CDPA	2	Transfers abroad need adequate protection in the recipient country or a listed derogation such as unambiguous consent.
Australia Privacy Act	1	Take reasonable steps so overseas recipients comply with APPs; discloser stays accountable. Whitelist power added in 2024.
Canada PIPEDA	1	Organization remains accountable and must use contracts or other means to ensure comparable protection by third-party processors.
Ghana DPA	1	No general transfer restriction; controllers must ensure foreign processors comply and list transfer countries at registration.
Philippines DPA	1	No adequacy regime; controller stays accountable for data sent abroad and must ensure comparable protection by contract or other means.
Chile Law 19,628	0	No international transfer restriction in the current text.
Hong Kong PDPO	0	No transfer restriction in force; s.33 never commenced. PCPD recommends model contract clauses.
India DPDP Act	0	Transfers allowed except to countries the government restricts by notification; conditions may be set by order.
California CCPA	–	Not addressed

In LPDP

• Article 32Competent body and legal regime
• Article 33Functions of the National Authority
• Article 34National Personal Data Protection Register
• Article 35Confidentiality
• Article 36Resources of the National Authority

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

In LPDP

• Article 10Principle of availability of remedies
• Article 24Right to protection (tutela)

  Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action.

• Article 25Right to compensation

  Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action.

• Article 37Sanctioning procedure
• Article 38Infringements
• Article 39Administrative sanctions
• Article 40Coercive fines

Private action across 39 laws

Peru Law 29733	2	Anyone harmed may claim compensation; denied rights can be pursued before the Authority or by habeas data action.
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.
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.
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.
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 LPDP

• Article 39Administrative sanctions

  Up to 100 UIT (about PEN 535,000, roughly USD 145,000), not exceeding 10% of prior-year gross income.

• Article 40Coercive fines

Maximum fine across 39 laws

Peru Law 29733	2	Up to 100 UIT (about PEN 535,000, roughly USD 145,000), not exceeding 10% of prior-year gross income.
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.
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.
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.
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.