Regulatory compliance in the age of data privacy: A comparative study of the Nigerian and U.S. legal landscapes

Abstract

This comparative study delves into the intricate regulatory compliance mechanisms governing data privacy in Nigeria and the United States. Employing a qualitative methodology, this research synthesizes existing literature and case studies to highlight the pivotal role of data protection regulations in safeguarding personal information in an increasingly digital world. The analysis begins with an exploration of the conceptual framework of data privacy, emphasizing key principles such as transparency, accountability, and data minimization. It then meticulously examines the Nigerian Data Protection Regulation (NDPR) and the diverse U.S. legal landscape, including the California Consumer Privacy Act (CCPA) and the Health Insurance Portability and Accountability Act (HIPAA). The main findings reveal significant differences in regulatory approaches, with Nigeria's centralized enforcement by the National Information Technology Development Agency (NITDA) contrasting sharply with the U.S.'s fragmented state and federal oversight. Case studies underscore the challenges faced by both jurisdictions in ensuring compliance, ranging from resource constraints in Nigeria to the complexities of navigating multiple regulatory requirements in the U.S. The study concludes that while both countries emphasize the importance of data privacy, their divergent legal landscapes reflect unique cultural, economic, and operational contexts. The research recommends harmonizing data protection standards, enhancing enforcement mechanisms, and fostering greater public awareness to address the evolving challenges of data privacy. This study contributes to the global discourse on data privacy by offering insights into the strengths and weaknesses of different regulatory frameworks, thereby providing a roadmap for policymakers, businesses, and other stakeholders to navigate the complexities of data privacy compliance. Keywords: Data Privacy, Regulatory Compliance, Nigeria, United States, Data Protection, Legal Frameworks.