The California Consumer Privacy Act of 2018 was passed last year and is due to come into effect in January 2020. It has been widely touted as radical initiative put forward in the wake of the Cambridge Analytica scandal as a way to address the vulnerability of personal information to misuse when it is shared on the internet.
How do its protections compare with the EU’s General Data Protection Regulation 2016, in operation from May last year, which has also been touted as a radical piece of data protection legislation? Which of these might provide a better model for Australia? Or are current law reform initiatives being mooted in Australia, including the Productivity Commission’s ‘consumer data right’ and ACCC’s recommendations in its draft Digital Platforms inquiry report, preferable for our purposes?
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