GDPR
EU regulation for personal data protection and privacy
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
GDPR governs EU data protection with global reach via DPAs, while UK GDPR adapts it post-Brexit for UK enforcement by ICO. Companies adopt both for compliance with EU/UK individuals' data, ensuring extraterritorial rules, rights, and penalties up to 4% turnover.
GDPR
Regulation (EU) 2016/679 General Data Protection Regulation
Key Features
- Extraterritorial scope applies to non-EU organizations
- Accountability principle requires demonstrating compliance
- Fines up to 4% of global annual turnover
- Enhanced data subject rights including erasure
- 72-hour personal data breach notification requirement
GDPR UK
UK General Data Protection Regulation (UK GDPR)
Key Features
- Seven core processing principles with accountability
- Enforceable data subject rights including portability
- Mandatory Records of Processing Activities (RoPA)
- 72-hour personal data breach notification to ICO
- Risk-based DPIAs for high-risk processing
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GDPR Details
What It Is
General Data Protection Regulation (GDPR), or Regulation (EU) 2016/679, is a binding EU regulation modernizing personal data protection. It has broad extraterritorial scope, applying to any entity processing EU residents' data globally. GDPR employs a risk-based, accountability-focused approach to ensure lawful processing in the digital era.
Key Components
- **Seven core principleslawfulness/fairness/transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, accountability.
- **Data subject rightsaccess, rectification, erasure ("right to be forgotten"), portability, objection, restriction.
- Obligations include DPIAs, Records of Processing Activities (ROPA), DPO appointment, 72-hour breach notifications.
- Enforced by supervisory authorities with fines up to €20M or 4% global turnover.
Why Organizations Use It
Mandatory compliance avoids massive penalties and legal risks. Builds customer trust, mitigates breach impacts, enables secure global data flows, enhances reputation as privacy leader, influences worldwide standards like LGPD/CCPA.
Implementation Overview
Gap analysis, policy/process redesign, staff training, tech upgrades (e.g., pseudonymization). Applies to all sizes handling EU data, cross-industry, globally. No formal certification; requires ongoing DPA audits, continuous monitoring. Typically 18-24 months initial rollout for mid-large firms.
GDPR UK Details
What It Is
UK GDPR (UK General Data Protection Regulation) is the UK's post-Brexit data protection law, adapting EU GDPR via the Data Protection Act 2018. It mandates a risk-based, accountability-focused framework for processing personal data of UK individuals, enforced by the ICO.
Key Components
- **Seven core principleslawfulness, purpose limitation, minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.
- Individual data subject rights (access, rectification, erasure, portability, objection).
- Controller/processor obligations (RoPAs, contracts, DPIAs, security, breaches).
- No fixed controls; compliance via demonstrable governance, fines up to 4% global turnover.
Why Organizations Use It
- Legal requirement for UK-established or targeting entities.
- Mitigates fines (£17.5M max), reputational damage, civil claims.
- Builds trust, enables data-driven innovation, streamlines cross-border operations.
Implementation Overview
- Phased: mapping (RoPA), policies, training, DPIAs, vendor contracts.
- Applies to all sizes handling UK personal data; ongoing audits, no certification.
Key Differences
| Aspect | GDPR | GDPR UK |
|---|---|---|
| Scope | Personal data of EU individuals globally | Personal data of UK individuals globally |
| Industry | All sectors, EU-wide with extraterritorial | All sectors, UK-focused with extraterritorial |
| Nature | EU regulation, enforced by national DPAs/EDPB | UK-domesticated regulation, enforced by ICO |
| Testing | DPIAs, audits by DPAs, consistency mechanisms | DPIAs, ICO audits and prior consultations |
| Penalties | Up to €20M or 4% global turnover | Up to £17.5M or 4% global turnover |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GDPR and GDPR UK
GDPR FAQ
GDPR UK FAQ
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