USA vs. India: Internet Privacy Laws
Almost every country in the world has internet privacy regulations. Although the scope and complexity might differ, the idea is to ensure online users based within a region have their information reliably safeguarded and managed.
That brings us to two countries that are the focus of this blog post: the US and India.
How do the privacy laws in these nations differ from each other? If you’re curious about this question, we provide the answers below.
Internet Privacy Laws in the United States: An Overview
There’s no single regulation in the US that addresses data privacy for all states and business industries. Instead, the country relies on different laws.
These legislations range from state-specific legislation to industry-based policies and other federal regulations.
Despite the abundance of internet privacy laws in the country, most US residents still take responsibility for their online security.
That said, below are some of the most popular internet privacy laws in America:
The CLOUD Act
The CLOUD Act is an amendment on the Stored Communications Act (SCA).
It gives US law enforcement authorities the right to access data stored and controlled by American tech companies in any of their servers, including those located overseas.
The California Consumer Privacy Act (CCPA)
The CCPA is a state law for residents of California.
It gives them specific rights regarding the personal data businesses collect from them, such as the right to know, delete, and opt out of having their information sold to third parties.
Still, it’s quite common to find many Americans connecting to Surfshark’s servers across the country to browse the web in a bid to protect their digital footprint.
The Health Insurance Portability and Accountability Act (HIPAA)
This is an industry-specific regulation that mainly applies to healthcare providers.
It aims to protect patient information, limiting how it is used and shared, with confidentiality being a necessity.
Internet Privacy Laws in India: The Full Scope
Compared to America, India’s internet privacy scene is still evolving. In fact, it was only recently that government authorities started having serious conversations around this subject, largely due to the rise in cybercrime in the country.
Prior to recent regulations, only the Information Technology Act addressed data privacy. However, a Supreme Court ruling in 2017 led to the development of broader laws to protect citizens.
Among the regulations introduced is the Digital Personal Data Protection Act (DPDPA). This is India’s version of the EU’s GDPR, focusing on the rights of individuals when it comes to their personal data and how companies collect and process this information.
It also has provisions for handling data breaches and stricter privacy requirements for large companies.
To further secure the personal data of citizens, the Indian government released the Digital Personal Data Protection Rules in January 2025. This legislation will aid the implementation of the DPDPA.
Conclusion
The US and India differ when it comes to internet privacy laws. While America has a more established legal framework, with laws at federal, state, and industry levels, India is still evolving.
The Digital Personal Data Protection Act, alongside the 2025 draft rules, are a step in the right direction for the country, as it aims to develop online privacy laws more in tune with global standards.
