Adam Kardash hosted an insightful discussion about the similarities and differences between Canada's proposed Consumer Privacy Protection Act (CPPA) and the EU's General Data Protection Regulation (GDPR). Featuring two experts from the Centre for Information Policy Leadership (CIPL) at Hunton Andrews Kurth LLP, Bojana Bellamy, President, and Mark Smith, Manager of Privacy and Data Policy, the comparative analysis of the two statutory frameworks considered a broad range of questions, such as
- how does the structure of the proposed CPPA compare to that of the GDPR, including with respect to the rights of individuals, the concept of accountability and adopting a risk-based approach?
- how do the enforcement regimes compare and what impact has the regime under the GDPR had on the privacy arena in Europe?
- what role do the concepts of privacy by design and privacy impact assessments play in the two frameworks?
- how do each of the frameworks establish a lawful basis for processing and how do the consent and legitimate interest models differ?
AccessPrivacy has commissioned and is working in collaboration with CIPL to conduct a more formal and thorough comparative analysis of the two frameworks. Details about this forthcoming study will be made available in due course.
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