Examination of personal data protection regimes in developing countries: comparative study of Malaysia, Pakistan and Bangladesh with reference to GDPR
Muhammad Abdullah Fazi, Mohammad Belayet Hossain, Yasir Aleem, Ridoan KarimPurpose
This study aims to examine and compare the personal data protection regimes of Malaysia, Pakistan and Bangladesh with the aim of identifying regulatory strengths, weaknesses and emerging trends in developing country approaches to privacy governance with reference to global data protection standards, particularly the European Union’s General Data Protection Regulation (GDPR).
Design/methodology/approach
This paper adopts a doctrinal and comparative legal methodology, analyzing statutory frameworks, draft legislation and regulatory structures in the three jurisdictions. The comparison focuses on scope, individual rights, regulatory independence and enforcement mechanisms.
Findings
The analysis demonstrates that while all three jurisdictions reflect increasing convergence with international data protection principles, significant structural deficiencies remain. Malaysia’s regime is limited in scope to commercial transactions and excludes state actors. Pakistan’s framework is more expansive but remains unimplemented and institutionally uncertain. Bangladesh’s proposed legislation suffers from definitional ambiguity and extensive executive control. Compared with the GDPR, all three regimes exhibit weaknesses in accountability, regulatory independence and enforceability.
Research limitations/implications
This study focuses on three selected developing jurisdictions and relies primarily on doctrinal analysis of legislative frameworks and policy documents. Future research may expand the comparative scope to include additional developing and developed jurisdictions and evaluate the practical implementation of these laws following enactment.
Practical implications
The findings provide guidance for policymakers, regulators and legislators seeking to strengthen data protection governance in developing countries. This study highlights the importance of independent supervisory authorities, comprehensive data subject rights, effective enforcement mechanisms and clear limitations on governmental exemptions.
Social implications
As digital economies continue to expand, effective data protection frameworks play a crucial role in safeguarding individual privacy, enhancing public trust in digital governance and promoting responsible data-driven innovation. Strengthening legal protections for personal data contributes to greater accountability, transparency and protection of fundamental rights in the digital age.
Originality/value
This study contributes to the literature by providing a systematic comparative analysis of three developing-country regimes at different stages of legislative evolution and by evaluating them against internationally recognized data protection standards.