A Comparative Study with GDPR, HIPAA, CCPA, PIPEDA and DPDPA

A turning point in India’s path towards protecting personal privacy is the Digital Personal Data Protection Act, 2023. The Act’s main flaws are absence of mandatory consent for data sharing, lack of local data storage restrictions, possible government overreach, inaccurate criteria for overseas data transfer, and inadequate enforcement mechanisms. These flaws have been examined in the work. This research gives practical lessons for India’s regulatory environment by means of comparative analysis of global data protection laws including General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Health Insurance Portability and Accountability Act (HIPAA), and Personal Information Protection and Electronic Documents Act (PIPEDA). The study assesses the Data Protection Draft Rules, 2025 ability to solve this flaws and guarantee a mix of privacy, government and economic development. The research ends with specific suggestion to improve individual rights, encourage responsibility, and match India’s data protection system with international norms, therefore insuring its resilience in a time of changing technological complexity.