The Bill of Data Protection and GDPR 2018: A Comparative Study

Today, Iran does not have a comprehensive law regarding digital data protection. The Bill to protect and protect data and personal information based on the General Data Protection Regulation (GDPR) - European Union 2018 - was developed and submitted to the parliament in 2020. This Bill is supposed to eliminate the lack of law in the field of data protection, but it has yet to follow many of the general principles of GDPR and has adopted the opposite position, which is considered to be very detrimental to data subjects. The main question of this research is what are the problems and gaps in the general principles of this plan with an adaptive approach to the general data protection regulations. The present essay, with a descriptive-analytical and inferential method, and by studying recent works and cases in the field of European data protection, aims to show the gaps and significant problems in the designed principles of this project. In short, many articles of the Bill, such as articles 10, 11, 12, and 48, need to be amended and clearly contradict the current legal foundations and relevant laws.