Comparative Legal Analysis of Personal Data in the Legislation of Uzbekistan, Europe and the USA

Abstract

This article presents a comprehensive comparative analysis of the legal frameworks governing the protection of special categories of personal data in Uzbekistan, the European Union, and the United States. The study examines the Law of the Republic of Uzbekistan “On Personal Data” (2019), the European Union’s General Data Protection Regulation (GDPR), and the sectoral approach adopted in the United States through HIPAA and state-level legislation such as the California Consumer Privacy Act. Through doctrinal legal analysis of legislative provisions, examination of enforcement cases in Europe, and comparative methodology, the research identifies significant gaps in Uzbekistan's current legal framework, particularly the absence of the right to be forgotten, inadequate data breach notification requirements, and insufficient penalties for violations. The article concludes with four specific legislative recommendations to strengthen Uzbekistan’s personal data protection regime and align it with international best practices.