Compare jurisdictions

Side-by-side view of the obligations each covered law imposes, grouped by category. Use this to spot where requirements overlap (one well-written control often satisfies multiple jurisdictions).

Category πŸ‡ͺπŸ‡ΊEuropean Union / EEA πŸ‡¬πŸ‡­Ghana πŸ‡°πŸ‡ͺKenya πŸ‡³πŸ‡¬Nigeria πŸ‡ΊπŸ‡ΈUnited States (California)
Governance & Accountability
  • GDPR-Art-37 Appoint a Data Protection Officer (DPO) where required

    A DPO is required for public authorities, large-scale monitoring, or large-scale special-category data processing.

  • GDPR-Art-5 Adhere to the principles of processing

    Lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.

  • GH-Principles Apply the eight data protection principles

    Accountability, lawfulness, specification of purpose, compatibility of further processing, quality, openness, safeguards, data subject participation.

  • KE-Principles Apply data protection principles

    Lawfulness, purpose limitation, minimisation, accuracy, storage limitation, integrity/confidentiality.

  • NG-DPO Appoint a Data Protection Officer where required

    Controllers of major importance and processors of high-risk data must appoint a DPO and publish their contact.

  • NG-Principles Observe principles of personal data processing

    Lawfulness, fairness, transparency, purpose specification, accuracy, storage limitation, integrity and confidentiality, accountability.

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Lawful basis & consent
  • GDPR-Art-6 Establish a lawful basis for each processing activity

    Identify and document one of the six lawful bases for every processing activity (consent, contract, legal obligation, vital interests, public task, legitimate interests).

  • GH-Consent Obtain consent or rely on a lawful processing ground

    Processing requires consent or another lawful ground (contract, legal obligation, vital interests, public interest, legitimate interests).

  • KE-Consent Establish a lawful basis

    One of: consent, contract, legal obligation, vital interests, public task, legitimate interests.

  • NG-Lawful Establish a lawful basis

    One of: consent, contract, legal obligation, vital interests, public interest, legitimate interests.

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Transparency & notices
  • GDPR-Art-12 Provide transparent information to data subjects

    Provide a concise, intelligible privacy notice covering identity of controller, purposes, legal basis, recipients, retention, rights, and contact for the DPO.

  • GH-Notice Provide notice to data subjects at collection

    Inform subjects of the purposes, recipients, rights, consequences of refusal, and contact for the controller.

  • KE-Notice Provide information to data subjects

    Notify subjects of rights, purposes, recipients, retention, and contacts.

  • NG-Notice Provide privacy information to data subjects

    Notify subjects of identity, purposes, recipients, retention, rights, and NDPC complaint channel.

  • CCPA-Notice Provide notice at or before collection

    Inform California consumers of categories collected, purposes, retention, and rights.

Data subject rights
  • GDPR-Art-15 Honor data subject rights within one month

    Access, rectification, erasure, restriction, portability, objection, and opt-out of automated decisions must be processed within one calendar month (extendable by two months for complexity).

  • GH-Rights Facilitate data subject rights of access and correction

    Data subjects may access their data, request correction, and object to processing.

  • KE-Rights Respect data subject rights

    Access, rectification, erasure, restriction, portability, objection to automated decision-making.

  • NG-Rights Honour data subject rights

    Access, rectification, erasure, restriction, portability, objection, opt-out of automated decisions.

  • CCPA-OptOut Provide a "Do Not Sell or Share My Personal Information" link

    Businesses must provide a clear, conspicuous Do-Not-Sell/Share link and honor Global Privacy Control signals.

  • CCPA-Rights Honor consumer rights to know, delete, correct, and limit

    Within 45 days (extendable by 45): access, deletion, correction, and limit use of sensitive personal information.

Security of processing
  • GDPR-Art-32 Implement appropriate technical and organisational measures (TOMs)

    Encryption, pseudonymisation, availability/integrity, regular testing, and ability to restore availability.

  • GH-Security Safeguard data against loss and unauthorised access

    Reasonable technical and organisational measures to preserve integrity and confidentiality of personal data.

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  • NG-Security Implement appropriate technical and organisational measures

    Protect against unauthorised access, loss, destruction, alteration, or disclosure.

  • CCPA-Security Implement reasonable security procedures

    Protect personal information from unauthorised access, destruction, use, modification, or disclosure.

Breach notification
  • GDPR-Art-33 Breach notification within 72 hours

    Personal data breaches must be notified to the supervisory authority within 72 hours of becoming aware, and affected data subjects notified if high risk.

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  • KE-Breach Notify the ODPC of breaches within 72 hours

    Controllers must notify the ODPC within 72 hours of becoming aware; data subjects where there is real risk of harm.

  • NG-Breach Notify the NDPC of breaches within 72 hours

    Notify the NDPC within 72 hours of becoming aware; data subjects where there is real risk of harm.

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International transfers
  • GDPR-Chap-V Use a valid transfer mechanism for data leaving the EEA

    Transfers outside the EEA require an adequacy decision, SCCs, BCRs, or a valid derogation; complete a Transfer Impact Assessment where applicable.

  • GH-Transfers Ensure lawful cross-border transfers

    Transfers to countries without an adequate regime require safeguards or consent.

  • KE-Transfers Ensure lawful cross-border transfers

    Transfers out of Kenya require adequacy, appropriate safeguards, or an applicable exemption.

  • NG-Transfers Ensure lawful cross-border transfers

    Transfers permitted on basis of adequacy, appropriate safeguards, binding instruments, or exceptions.

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DPIA / Risk assessment
  • GDPR-Art-35 Perform DPIA for high-risk processing

    A Data Protection Impact Assessment is mandatory for processing likely to result in high risk to rights and freedoms (profiling, large-scale special category, children's data, public monitoring).

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  • KE-DPIA Complete DPIA for high-risk processing

    DPIAs required for processing likely to result in high risk to rights and freedoms.

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Processors & sub-processors β€” β€” β€” β€”
  • CCPA-Contracts Flow-down contractual terms to service providers and contractors

    Written contracts with required clauses (purpose limitation, no sale, audit rights).

Record of processing
  • GDPR-Art-30 Maintain Records of Processing Activities (ROPA)

    Controllers and processors must maintain a written register of processing activities listing purposes, categories of data and subjects, recipients, transfers, retention, and security measures.

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  • NG-ROPA Maintain records of processing activities

    Controllers and processors of major importance must maintain written processing records.

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Special categories / children β€” β€” β€” β€”
  • CCPA-Sensitive Provide "Limit Use" for Sensitive Personal Information

    Consumers may direct businesses to limit use of sensitive PI to what is necessary to perform services.

Regulator registration β€”
  • GH-Registration Register as a data controller with the Data Protection Commission

    All data controllers processing personal data in Ghana must register with the DPC and renew annually.

  • KE-Registration Register as data controller or processor with the ODPC

    Controllers and processors above a prescribed threshold must register with the ODPC (renewable every 2 years).

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Sourced from the same content engine that powers the assessment. Cells marked "β€”" mean the law in that column has no specific requirement in that category β€” not that anything is exempt.