Global Privacy Regulations
Navigate the complex landscape of privacy and cookie consent laws across different regions
Regulations at a Glance
Compare key aspects of major privacy regulations around the world
| Regulation | Region | Consent Required | Right to Access | Right to Delete | Penalties |
|---|---|---|---|---|---|
| GDPR 2018 | European Union | Up to €20M or 4% of global revenue | |||
| CCPA/CPRA 2020/2023 | California, USA | $2,500-$7,500 per violation | |||
| LGPD 2020 | Brazil | Up to 2% of revenue in Brazil (max R$50M) | |||
| PIPEDA 2000 | Canada | Varies by province | |||
| POPIA 2020 | South Africa | Up to R10M or imprisonment | |||
| PDPA 2012/2019 | Singapore/Thailand | Up to S$1M (SG) or ฿5M (TH) |
GDPR (General Data Protection Regulation)
European Union, 2018
Key Requirements
- Explicit consent required before setting non-essential cookies
- Detailed information about data collection and processing
- Easy-to-use consent withdrawal mechanism
- Data subject rights (access, deletion, portability)
- 72-hour breach notification
Cookie Banner Requirements
- No pre-ticked boxes for consent
- Granular consent options for different cookie categories
- Equal prominence for "Accept" and "Reject" options
- No cookie wall (blocking access without consent)
UK GDPR & ePrivacy Directive
United Kingdom, Post-Brexit
Key Requirements
- Similar to EU GDPR with UK-specific adaptations
- ICO (Information Commissioner's Office) enforcement
- Explicit consent for cookies (from ePrivacy Directive)
- Potential divergence from EU GDPR over time
Recent Developments
The UK is exploring its own data protection framework post-Brexit, potentially creating a more business-friendly approach while maintaining high standards of data protection.
ePrivacy Regulation (Upcoming)
European Union, Proposed
The ePrivacy Regulation is set to replace the current ePrivacy Directive and will work alongside the GDPR to provide specific rules for electronic communications. It aims to streamline cookie consent requirements and potentially introduce browser-level consent mechanisms.
Stay Compliant Worldwide with CookieGuard
Our platform automatically adapts to visitor location, applying the appropriate regulatory requirements for cookie consent. No matter where your users are located, CookieGuard helps you maintain compliance.
