K-PIPA
South Korea's stringent data protection regulation
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
K-PIPA mandates consent-centric protections for Korean data handlers with CPOs and 72-hour breaches, while GDPR UK enforces accountability-driven principles for UK processors via DPIAs and rights. Companies adopt them for legal compliance, market access, and trust in Asia-Pacific and UK operations.
K-PIPA
Personal Information Protection Act
Key Features
- Mandatory CPO appointment with independence guarantees
- Granular explicit consent for sensitive data transfers
- 72-hour breach notifications to data subjects
- Extraterritorial reach targeting foreign Korean services
- Revenue-based fines up to 3% annual global revenue
GDPR UK
UK General Data Protection Regulation (UK GDPR)
Key Features
- Seven core data processing principles with accountability
- Enforceable individual data subject rights
- Risk-based DPIAs for high-risk processing
- 72-hour personal data breach notification to ICO
- Fines up to 4% of global annual turnover
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
K-PIPA Details
What It Is
K-PIPA (Personal Information Protection Act) is South Korea's comprehensive data protection regulation, enacted in 2011 with major amendments in 2020, 2023, and 2024. It governs collection, use, storage, transfer, and destruction of personal information, including sensitive and unique ID data, for all handlers—domestic and foreign targeting Koreans. Employs a consent-centric, risk-based approach with principles like transparency, purpose limitation, and data minimization.
Key Components
- **Core pillarsConsent management, CPO oversight, data subject rights, security safeguards, cross-border transfers.
- Granular requirements without fixed control count; mandates CPOs, encryption, breach response.
- Built on GDPR-aligned principles but emphasizes explicit opt-ins.
- Enforced by PIPC via fines up to 3% revenue; no certification but ISMS-P for transfers.
Why Organizations Use It
Legal compliance avoids massive fines (e.g., Google's KRW 70B); enables EU adequacy flows. Mitigates breach risks, builds trust in privacy-sensitive market. Strategic for multinationals entering Korea, fostering innovation via pseudonymization.
Implementation Overview
Phased: gap analysis, CPO appointment, data mapping, PbD integration, training, audits. Applies universally to businesses processing Korean data; high complexity for large entities. No formal certification but PIPC guidelines and voluntary tools recommended.
GDPR UK Details
What It Is
UK GDPR (UK General Data Protection Regulation) is the UK's post-Brexit adaptation of the EU GDPR, a binding regulation enforced by the ICO. It governs personal data processing with a risk-based, accountability-focused approach, applying to UK-established and extraterritorial organizations targeting UK individuals.
Key Components
- Seven core principles: lawfulness, purpose limitation, minimisation, accuracy, storage limitation, security, accountability.
- Data subject rights (access, rectification, erasure, portability, objection).
- Controller/processor obligations, DPIAs, lawful bases, breach notification.
- No certification; compliance via demonstrable records (RoPA), fines up to 4% global turnover.
Why Organizations Use It
- Mandatory for legal compliance, avoiding ICO fines (£17.5M max).
- Enhances risk management, trust, operational efficiency.
- Builds reputation, enables cross-border operations.
Implementation Overview
Phased approach: governance, data mapping (RoPA), policies, training, DPIAs, audits. Applies to all sizes handling UK data; ongoing monitoring required, no formal certification.
Key Differences
| Aspect | K-PIPA | GDPR UK |
|---|---|---|
| Scope | Personal info of Korean residents, sensitive/UID data | Personal data of UK individuals, broad principles |
| Industry | All sectors targeting Koreans, extraterritorial | All sectors targeting UK, extraterritorial reach |
| Nature | Mandatory Korean law, PIPC enforcement, criminal sanctions | Mandatory UK regulation, ICO enforcement, administrative fines |
| Testing | CPO audits, security guidelines, no private DPIAs | DPIAs for high-risk, regular security assessments |
| Penalties | 3% revenue or KRW 3bn, up to 5 years imprisonment | 4% global turnover or £17.5M, corrective orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about K-PIPA and GDPR UK
K-PIPA FAQ
GDPR UK FAQ
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