Regional Models of Legal Regulation of Data Protection in the EU and APEC Countries

The article analyzes the models of legal regulation of personal data protection that have developed in the EU and the countries of the Asia–Pacific region. The subject of the study is a comparative legal analysis of the theoretical and practical aspects of personal data protection in the EU and APEC countries. The conclusion is made about a narrower concept of «privacy protection» in relation to «data protection», which includes other basic rights and freedoms of citizens and all types of data, regardless of their relationship to the sphere of private life. Based on a comparative analysis of the main acts in the field of personal data protection in force in the EU and APEC countries (GDPR and CBPR), the main difference in the purpose of legal regulation is highlighted: in GDPR, this is the protection of users and the establishment of their control over personal data, and in CBPR—the development of economic turnover, in particular, electronic commerce. Additional differences in the models of legal regulation of data protection in the EU and APEC countries on the subject of application, methods of data transmission, and the field of personal data are considered.