Abstract
All six Central Asian countries—Kazakhstan, Kyrgyz Republic, Tajikistan, Turkmenistan, Uzbekistan, and Mongolia—have new or recently revised data privacy laws. These legal regimes have received little critical analysis, with existing regional studies only mentioning them but without detailed discussion or comparison. This article aims to fill that gap.
Considering the strategic location between Russia (five are ex-SSRs) and China (near neighbours on the Digital ‘Belt & Road’) by 2024, not only Russia and China are contesting influence in Central Asia, but the EU is also increasing economic cooperation, and deepening political ties with Central Asian countries.
The context in which these privacy laws must be understood forms part of a broader global conflict over the regulation of technology. One which also requires comparison of digital infrastructure and surveillance technologies, two areas in which China is shown to be dominant in Central Asia.
A comparison of the data privacy laws of the six countries is made against more than 30 principles found in international data privacy agreements (particularly the DPD, GDPR, and Convention 108+). The Central Asian laws are shown to be close to the global average for countries that have enacted data privacy laws, with Uzbekistan, Mongolia, and Kazakhstan having stronger laws than the other three countries.
Enforcement of these data privacy laws is occurring, but shown to be in its infancy, with low penalties for breaches, and minor evidence of enforcement only in the Kyrgyz Republic, Kazakhstan, and Mongolia.
Considering the strategic location between Russia (five are ex-SSRs) and China (near neighbours on the Digital ‘Belt & Road’) by 2024, not only Russia and China are contesting influence in Central Asia, but the EU is also increasing economic cooperation, and deepening political ties with Central Asian countries.
The context in which these privacy laws must be understood forms part of a broader global conflict over the regulation of technology. One which also requires comparison of digital infrastructure and surveillance technologies, two areas in which China is shown to be dominant in Central Asia.
A comparison of the data privacy laws of the six countries is made against more than 30 principles found in international data privacy agreements (particularly the DPD, GDPR, and Convention 108+). The Central Asian laws are shown to be close to the global average for countries that have enacted data privacy laws, with Uzbekistan, Mongolia, and Kazakhstan having stronger laws than the other three countries.
Enforcement of these data privacy laws is occurring, but shown to be in its infancy, with low penalties for breaches, and minor evidence of enforcement only in the Kyrgyz Republic, Kazakhstan, and Mongolia.
| Original language | English |
|---|---|
| Pages (from-to) | 67-90 |
| Number of pages | 24 |
| Journal | International Data Privacy Law |
| Volume | 15 |
| Issue number | 1 |
| DOIs | |
| Publication status | Published - Feb 2025 |
Bibliographical note
Copyright the Author(s) 2025. Version archived for private and non-commercial use with the permission of the author/s and according to publisher conditions. For further rights please contact the publisher.Keywords
- privacy
- data protection
- Central Asia
- Belt and Road Initiative
- SSRs