Comparison Of Personal Information Protection Between GDPR And CCPA

With the development of Internet technology and the application of big data,the collection,dissemination and utilization of information has become more convenient,and people's private life has become more transparent,bringing with it concerns about information leakage or illegal handling of personal information.Information,as a vital emerging resource in modern society,is regarded as a new digital currency in the context of digital economy,which is valued by more and more countries or regions.Some countries have been carrying out research on the protection of personal information since the 1960s,and are still strengthening the protection of personal information,so they have accumulated rich theoretical and practical experience.However,the legal research on information protection in China started relatively late,and the legislation is too scattered and not strong in practice,which is in contradiction with the information industry with rapid development.In order to solve this problem,it is necessary to learn from the good experience outside the region,learn from the latest legislation in Europe and the United States,and combine our own national conditions and actual conditions to constantly improve the legal protection of personal information in China.Apart from the introduction and conclusion,the main body of this paper consists of four chapters,including four parts.The first part mainly discusses the basic theory about personal information protection,in order to better explore the information protection,the need to set the three concepts about personal information,through comparing the legislation of the European Union,the United States and China about the definition of the concept of "personal information" mode,the right base and the constitutional basis,for the research of personal information protection lay a solid legal basis.The second part through to the General Data Protection ordinance(General Data Protection Regulation,hereinafter referred to as GDPR)and the United States California consumer privacy act(California consumer privacy law,hereinafter referred to as the CCPA)new legislation in the two,the comparative analysis of two law in legislation,information subject of rights,different Regulation mode and right remedy,and their respective advantages and disadvantages,to provide objective basis for the future of personal information Protection legislation in China.The third part mainly describes the current situation and deficiencies of information protection in China and reflects on the gains and losses of the current legislative work.In the last part,on the basis of learning from GDPR and CCPA,and combining with the specific situation of China,it summarizes the enlightenment of the two laws on the legislative level,regulatory system and rights relief of China's future personal information protection law.Thesis mainly using the method of literature research,comparative analysis,to conduct a detailed analysis and carding the main content of GDPR and CCPA,the European Union and the United States as the pioneer of information protection and research,the latest effect greatly of the two laws guarantee the jurisdiction of the citizen's right of personal information,the information protection legislation in our country has a certain guiding significance.Although CCPA of the United States and GDPR of the European Union have great reference significance,we should also pay attention to the potential problems existing in these two legislations,demonstrate the applicability of their practices from an objective and critical perspective,and formulate a legal system for personal information protection that is suitable for local application in China.In 2020,the research on personal information protection in China will enter a new stage.Based on the current big data the realistic background of The Times,the risks of personal information,the call for protection of personal information is more and more demanding,we suggest to learn the good experience of Europe and the United States the latest legislation,considering our country's realistic national conditions,exploring the unification of personal information protection legislation,to strengthen the rights of information subjects and the improvement of the regulatory relief,hoping through the personal information protection mechanism of architecture,to realize the balance of the personal information protection and industrial development.