The article examines the European Union's human-centric model of digital privacy and its implications for Vietnam's evolving data protection framework. Drawing on European Union legal instruments, particularly the Charter of Fundamental Rights and General Data Protection Regulation (GDPR), the study distinguishes between the right to privacy and the right to personal data protection, highlighting how these are operationalized through constitutional guarantees, case law, and independent oversight. In contrast, Vietnam's legal architecture remains fragmented, lacking both institutional safeguards and meaningful user empowerment. Using comparative legal analysis, the article argues that Vietnam's upcoming Law on Personal Data Protection and Law on Data, while progressive in scope, still fall short of embracing a rights-based paradigm. The study calls for the constitutional recognition of privacy, the establishment of an independent data protection authority, and the institutionalization of digital rights as fundamental. It concludes that embedding human dignity and individual autonomy into digital governance is essential for building a democratic, trusted, and future-proof data ecosystem in Vietnam and beyond.
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Ngoc Tuan Tran
Ho Chi Minh City University of Law
Social Sciences & Humanities Open
Ho Chi Minh City University of Law
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Ngoc Tuan Tran (Mon,) studied this question.
synapsesocial.com/papers/6a0d4e9df03e14405aa99d7a — DOI: https://doi.org/10.1016/j.ssaho.2026.102926
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