Comparative analysis of AI and privacy laws in Europe and Asia : Identifying regulatory disparities and pathways for harmonisation
Abstract
This paper provides a comparative analysis of artificial intelligence (AI) and privacy legislations in Europe and Asia, aiming to identify and bridge existing regulatory disparities to facilitate international cooperation and interoperability. The analysis contrasts Europe’s rights-based regulatory frameworks, notably the General Data Protection Regulation (GDPR) and the recently enacted EU AI Act, with pragmatic and innovation-driven models evident in Asian jurisdictions such as India’s Digital Personal Data Protection Act 2023 (DPDP Act), proposed Digital India Act, China’s Personal Information Protection Law (PIPL), Japan’s Act on the Protection of Personal Information (APPI) and Singapore’s Personal Data Protection Act (PDPA). By exploring geopolitical, economic and legal influences shaping these diverse regulatory approaches, the paper delivers critical insights through targeted case studies, illustrating both practical challenges and successes in balancing innovation with robust privacy safeguards. Key issues examined include cross-border data transfer complexities, the necessity for interoperability and the establishment of trust frameworks. The paper critically evaluates ethical considerations, particularly around consent mechanisms, data ownership rights and algorithmic transparency, within each regional context. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.
The full article is available to subscribers to the journal.
Author's Biography
Lanx Goh is the Global Head of Privacy with Prudential. He was selected among the Top 10 Guardians of Cyber Space 2022 by Cyber Express and received the IAPP Vanguard Award (Asia) in 2023. He is also an Honorary Consul of Bulgaria to Singapore, and Adjunct Law Lecturer with the Singapore Management University, School of Law. Lanx currently sits on the IAPP Asia and CIPP/A Exam Development Advisory Boards, Cyber Express Advisory Board, IMDA Data Protection Trustmark Standards Development Working Group, MAS AI Working Group, 20Minds Editorial Board and CEEC Advisory Board.
Vinni Kalra Francis is the Senior Manager within Group Information Security & Privacy at Prudential. She is an experienced lawyer with over a decade of expertise in legal negotiations, contracting, and privacy and data protection. She holds prestigious certifications in privacy including Certified Information Privacy Professional/Europe and Certified Information Privacy Manager. Vinni has been designated Fellow of Information Privacy (FIP) by the International Association of Privacy Professionals (IAPP). In the information security domain, she is a qualified ISO 27001:2022 Lead Auditor, as well as an artificial intelligence (AI) governance professional and a qualified ISO 42001:2023 Lead Implementer.
