Artificial Intelligence and Personal Data Protection: A Comparative Legal Study of the EU, United States and Pakistan
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This paper aims to investigate the interplay of Artificial Intelligence with the aspect of personal data protection by making a comparative analysis of the three well-developed legal systems namely the European Union, United States and Pakistan. It seeks to determine how laws in these jurisdictions govern the relatively new data-intensive AI technologies while considering the factors of innovation and privacy. The gaps and inconsistency of the current regulatory framework are explored for critical points while the topics of automated decision-making, action of algorithms and cross-border data transfers are also emphasized. Using a doctrinal and functionalist approach, this paper assesses right-based regulation from the EU, sectoral and fragmented currents from the US and emerging models from Pakistan. It shows how the GDPR and the AI Act 2024 place the EU in a leadership role while presenting the US as a country of enforcement and Pakistan as a country in its infancy trying to embrace the new legal developments. Subjects like Article 22 GDPR, risk-based regulation of AI and compliance dilemmas for multinational businesses are discussed in detail. The dissertation also examines the effects of regulatory divergence on the business environment for international business, compliance and digital sovereignty. Some of the policies call for risk-tiered regulation, harmonisation by use of digital trade agreements, independent auditing and stakeholder governance. Finally, the dissertation provides a concept that is about the legal regulation of AI and advanced technology based on human rights legal frameworks that are compatible with other global legal systems. It postulates that if there is no proper and coordinated approach towards the regulation of AI, then AI has the potential to deepen Social digital divides and reduce the public faith in the democratic government and advancement in technology.