The transatlantic variants
👉India must be careful in picking up best practices from elsewhere in drafting a data protection law While the Americans and Europeans both call a sport football, they play a very different game. This difference is rooted not only in culture but in the rules of the game that provide rewards for goals, and penalties for breaching allowances. In the case of privacy regulations too, such a marked distinction is visible. With the European General Data Protection Regulation (GDPR) coming into effect on May 25, 2018, the absence of a comparable regulation across the Atlantic poses a question for India: What path should it take? Should it follow the U.S. or Europe? Or, in fact, should India take the lead in this regard? 👉American exceptionalism Last year, in November, the U.S. Supreme Court heard arguments in Carpenter v. United States, which many commentators termed as one of the most critical electronic surveillance case in decades. Among other finely threaded legal arguments ...