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Abstract

This note examines the privacy and data security regimes in three distinct systems: that of the United States, the European Union and in India. The strengths and deficiencies of these three systems are analyzed and used as a foundation for imagining and articulating the importance of a global data privacy regime. The note argues that the nature of data protection requires a global system that balances the values of these three different systems. Despite the challenges of international cooperation and the different priorities that each of these areas has regarding data security, an international system would be beneficial compared to the current differing systems.

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