DATA PROTECTION IN A GLOBALIZED WORLD: A COMPARATIVE ANALYSIS BETWEEN THE BRAZILIAN GENERAL DATA PROTECTION LAW AND THE NORTH AMERICAN REGULATORY MOSAIC

Abstract

This paper aims to delve deeper into the analysis of data protection in a globalized world, with an emphasis on a comparative analysis of the Brazilian General Data Protection Law and the North American regulatory landscape. This approach offers a comparative approach to both personal data protection models, focusing on the similarities and differences between these legal systems. To achieve this goal, this study employs a bibliographical research methodology, examining the works of renowned scholars in the field of data protection. In this analysis, renowned Brazilian jurists, including Daniel Aranha Correa, analyze the impacts of the law and its positioning in relation to international legislation, including the American one, highlighting the nuances and practical implications of these regulatory differences. Gustavo Gontijo investigates the adequacy of Brazilian legislation to international standards, particularly the General Data Protection Regulation, addressing the structural differences between these systems. Alexandre Câmara emphasizes the particularities of the law in comparison with the United States legal system, drawing parallels that elucidate the specificities of each perspective. This article analyzes how the aforementioned legal regulations resulted in advances in the protection of individuals' fundamental rights regarding their personal data. At the end, conclusions are presented that address the effectiveness of the work in achieving its objectives and the relevance of the study for understanding the legal complexities arising from global trends on the topic in question, in addition to providing support for the improvement of Brazilian legislation and international cooperation in this area.