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Vol. 18 Issue 2 (2022)

New Data Architectures in Brazil, China, and India: From Copycats to Innovators, towards a post-Western Model of Data Governance

Luca Belli

This paper explores the recent data protection evolutions in three leading emerging economies, Brazil, China, and India, to identify the contours of what may become a new post-Western Model of Data Governance.
The paper stresses that recent innovations introduced by these countries are particularly relevant for two reasons. First, the considerable geopolitical and economic weight they have at both regional and international level. In this perspective, the policy choices of these leading emerging economies are likely to be considered as models to which national and international frameworks may adapt in the future, especially in the Global South context. Second, for the pragmatic approach they adopt, to tackle the limits of dominant data protection models, using some of their strongest assets: namely, the Brazilian multistakeholder governance, the Chinese cybersecurity regulation, and the Indian technological expertise. Importantly, the countries’ approaches bring significant elements of novelty to data protection.
The paper identifies the main characteristics of the three national data architectures and the elements of novelty that are likely to inspire other frameworks: the new multistakeholder advisory body for the Brazilian data protection authority, the new Chinese data security framework, and the new Data Empowerment and Protection Architecture of India. It argues that the study of the data architectures of these countries is necessary not only to grasp how these very different giants are evolving, but also to understand the influence they will have on other countries at both regional and global levels.
The paper concludes by emphasising that, while Brazil, China, and India are not renowned for their commitment to data privacy, their approaches and their global relevance have the potential to give rise to a new “third way” in data governance, shaped by Global South leaders. Such a new approach can facilitate the emergence of a post-Western data architecture model.


Professor of Internet Governance and Regulation at Fundação Getulio Vargas (FGV) Law School, where he directs the Center for Technology and Society (CTS-FGV) and the CyberBRICS project. He is also editor of the International Data
Privacy Law Journal, published by Oxford University Press.

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