Personal data protection in emerging digital economies: regulatory convergence and divergence between Vietnam and Kazakhstan under international data governance standards

Abstract

As Vietnam and Kazakhstan deepen their cooperation in trade, investment, and digital transformation, the protection of personal data has become an important legal prerequisite for building digital trust and facilitating cross-border data flows. This article examines and compares the legal frameworks governing personal data protection in the two countries in light of international standards, including the GDPR, the OECD Privacy Guidelines, and the APEC Privacy Framework. Using a comparative legal methodology, the study analyzes data subject rights, accountability mechanisms, cross-border data transfers, and enforcement practices in both jurisdictions. The findings indicate that both countries have strengthened their legal frameworks and increasingly align with international data protection principles. However, significant differences remain regarding regulatory approaches, institutional governance, and cross-border data governance. Vietnam has developed a more comprehensive and rights-oriented framework, whereas Kazakhstan places greater emphasis on data sovereignty and localization. The article argues that stronger accountability mechanisms, improved enforcement, and greater regulatory harmonization are necessary to enhance digital trust and support sustainable digital economic cooperation between the two countries.