EXPERIENCE OF PERSONAL DATA PROTECTION IN THE USA AND ASIAN COUNTRIES (E.G. JAPAN, SINGAPORE)

Abstract

This article provides a comparative legal analysis of the mechanisms and specific features of legal regulation in the field of personal data protection in the United States and a number of Asian countries, including Japan and Singapore. The author highlights the role of personal data in the modern digital society and emphasizes the importance of safeguarding the right to privacy. The US experience is examined in detail from the perspective of the absence of a single comprehensive data protection act and the weak allocation of responsibilities between the private sector and public institutions. It is shown that data protection in the United States is mainly governed by sectoral legislation (healthcare, finance, education, etc.), while a unified legal regime at the federal level has not yet been formed.

Furthermore, the article demonstrates that in Asian countries, including Japan and Singapore, data protection systems have been aligned with international standards while being adapted to national cultural and legal traditions. The study analyses the institutional framework of data protection, the role of regulatory authorities, and issues of corporate responsibility. The article also considers the interaction between regional specificities and global integration trends, the need for international legal harmonization, and ensuring the secure cross-border flow of personal data. The author argues that, under conditions of globalization, it is necessary to align national legislation with international standards and to account for the interconnection of legal, technological and cultural factors in the field of data protection.

Keywords: personal data protection; privacy; USA; Japan; Singapore; legal regulation; digital society; international standards; data governance; comparative analysis.