Title: GDPR and Bangladesh's data privacy laws: a comprehensive analysis

Authors: Md. Zahurul Haq; Zainal Amin Bin Ayub; Abdel Rahman Ahmed AbdelRahman

Addresses: School of Law, UUM College of Law, Government and International Studies, Universiti Utara Malaysia, 06010 Sintok, Kedah Darul Aman, Malaysia ' School of Law, UUM College of Law, Government and International Studies, Universiti Utara Malaysia, 06010 Sintok, Kedah Darul Aman, Malaysia ' Department of International Relations, College of Arts, Humanities, and Social Sciences, University of Sharjah, Sharjah, UAE

Abstract: This article aims to conduct a comparative analysis of data privacy policies, specifically examining the European Union General Data Protection Regulation (GDPR) and Bangladesh's minimalistic legal framework, to assess their impact on data protection and privacy rights. The authors applied the functional method of comparative law to examine how the legal systems of the European Union and Bangladesh address the issues relating to data privacy and compare the outcomes achieved by each legal system. By examining the legal frameworks, principles, and practices, the article provides insights into how these distinct legal systems tackle data protection challenges and highlights potential differences in outcomes. Findings suggest that Bangladesh's data privacy legal regime shares several common principles with the GDPR. However, the primary issue stems from the absence of data subjects' ownership recognition under the Bangladeshi legal regime, rendering it less comprehensive in scope and fewer rights and protections to data subjects.

Keywords: General Data Protection Regulation; GDPR; data protection; data privacy; Bangladesh; data ownership; comparative analysis.

DOI: 10.1504/IJPLAP.2025.145300

International Journal of Public Law and Policy, 2025 Vol.11 No.2, pp.192 - 209

Received: 06 Oct 2023
Accepted: 06 Nov 2023
Published online: 31 Mar 2025 *

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