ANÁLISE COMPARADA DA NORMAS DE PROTEÇÃO DE DADOS DO BRASIL, DA UNIÃO EUROPEIA E DO ESTADO DA CALIFÓRNIA - EUA: LGPD X GDPR X CCPA LGPG x GDPR x CCPA

Abstract

This article makes a comparative analysis of the personal data protection standards in force in Brazil (LGPD), the European Union (GDPR) and the state of California, USA (CCPA). The methodology used involved a bibliographical review of the aforementioned legislations and a detailed comparison of their main aspects, concepts, territorial scope of each regulation, governmental data protection authorities, how the collection and processing of data from minors is handled, and which rights the regulations guarantee to data holders, mainly access, rectification and erasure of collected data. The objective of the research was to identify similarities and differences between the three regulations and evaluate their effectiveness in protecting personal data. The results indicate that, despite cultural and legal divergences between regions, there is a growing trend towards standardization of data protection standards, aiming for greater security and transparency in the processing of personal information. It is concluded that the CCPA entails punishments considered light in comparison to the LGPD and GDPR, which are more comprehensive and stricter in their sanctions. Harmonization of these standards can facilitate international trade and promote data protection on a global scale, although significant challenges remain in implementing these policies.