The Three Great Regimes: GDPR, China's Stack, and India's DPDP
Three regimes set the tone for the rest of the world, and each embodies a different philosophy. Europe's GDPR protects the individual and polices exports through an adequacy-and-contract machinery. China's three-law stack protects the state and treats data as a matter of national security, gating exports behind government assessment. India's DPDP charts a pragmatic middle path, localizing selectively while keeping the door to trade open. Faraday's read is that these are not merely three rulebooks but three theories of what data is for. Understand the theory and the specific clauses become predictable. Export controls reshape the global compute map, and these three are the master cartographers.
Knowledge check
How do the underlying philosophies of the EU's GDPR and China's data-law stack differ, and how does that difference show up in their transfer mechanisms?
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GDPR is grounded in individual privacy as a fundamental right, so its transfer mechanisms (adequacy decisions, standard contractual clauses, binding corporate rules) focus on ensuring the individual's protections travel with their data. China's stack is grounded in national security and state sovereignty over data, so its principal transfer mechanism is a government-administered security assessment, giving the state direct discretionary control over what leaves the country.