What question did this study set out to answer?

The paper aims to examine how the GDPR impacts data protection and cross-border data frameworks in ASEAN countries.

From fragmentation to interoperability: How the GDPR shapes ASEAN data privacy and cross-border data flows

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This comparative analysis explores GDPR influence on data protection in ASEAN, suggesting pathways for regulatory harmony.

The paper aims to examine how the GDPR impacts data protection and cross-border data frameworks in ASEAN countries.
Comparative doctrinal method
Assessment of legislative frameworks in Vietnam, Indonesia, Malaysia, and Singapore
Analysis of GDPR provisions related to international transfers, data subjects' rights, and accountability
ASEAN countries adopt core GDPR principles while maintaining their unique legal priorities
Vietnam shows a security-oriented approach, while Malaysia follows a 'data users' model
Hybridisation leads to convergence in concepts such as consent and data portability, but divergence in enforcement and cross-border restrictions

Minh Hoang Le (2026) studied this question.

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