Beyond Digital Protection(ism)

Abstract

What values and conceptualizations of data are being advanced through new data protection regulations in Asia? This article answers this question with a comparative analysis of data protection regulations in China, India, and South Korea. The article identifies four key dimensions of divergence: conceptualizations of personal and sensitive information, cross-border data transfer restrictions, state exceptions, and considerations for platforms. This leads to three conclusions: local notions of “privacy” are animated by complex domestic priorities and geopolitics, data protection regulations contribute to platform governance, and local exceptions to data protection regulations reveal diverse political strategies to manage citizen-state relations.