International Law and Immigration

Ca. Int'l Law Journal 2019, VOL. 27, NO. 2

A COMPARATIVE ANALYSIS OF DATA PROTECTION REQUIREMENTS IN THE EUROPEAN UNION AND THE US FOCUSING ON GERMANY AND CALIFORNIA

Dyann Heward-Mills*

Helga Turku**

I. INTRODUCTION

In May 2018, the European Union (EU) adopted the General Data Protection Regulation (GDPR), which aims to modernize and harmonize EU data protection laws across Europe. Other recent EU legislation on data protection includes the Data Protection Law Enforcement Directive1 (which protects data used by criminal law enforcement authorities) and the Data Protection Regulation (which protects data used by EU institutions and bodies).2 The EU has taken the view that rigorous data protection regulations are essential to safeguard the rights and freedoms of individuals in a democracy.3

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