The global data privacy landscape is a complex patchwork of regulations. For businesses operating in or selling to key markets like Texas, California, and the European Union, three acronyms dominate the compliance conversation: TDPSA, CCPA/CPRA, and GDPR.

A common question arises: "If we comply with the strictest law, like GDPR, are we covered for the others?" The answer is not so simple. While these laws share common goals of consumer empowerment and data protection, their differences in scope, rights, and core obligations are critical for any global business to understand.

As of September 2025, all these laws are in full effect. This article provides a clear comparison to help you build a cohesive and effective global compliance strategy.

At a Glance: TDPSA vs. GDPR vs. CCPA/CPRA

Key Differences and Similarities Explained

1. Scope and Applicability: Who is Covered?

• GDPR: Has the broadest reach. It doesn't matter where your company is located; if you process the personal data of someone in the EU, the GDPR applies to you.

• CCPA/CPRA: Applies to for-profit businesses that "do business" in California and meet one of three thresholds: a certain annual gross revenue, processing the data of a large number of consumers, or deriving a significant percentage of revenue from selling/sharing personal data.

• TDPSA: Applies broadly to those who conduct business in Texas or target Texas residents, with no revenue threshold. However, its most unique feature is a broad exception for small businesses as defined by the U.S. Small Business Administration, making it less burdensome for smaller companies than the CCPA.

2. The Crucial Divide: Handling Sensitive Data

This is one of the most significant operational differences between the laws.

• GDPR and TDPSA (The "Opt-in" Model): Both laws are aligned here. They require businesses to obtain a consumer's clear, affirmative consent before collecting or processing sensitive data (e.g., health information, biometric data, precise geolocation). This is a high bar and requires proactive consent mechanisms.

• CCPA/CPRA (The "Opt-out" Model): California takes a different approach. It gives consumers the "Right to Limit the Use and Disclosure of Sensitive Personal Information." This means a business can collect the data without prior opt-in consent, but must provide consumers with a clear way to opt out of its use for purposes other than providing the core service.

3. Consumer Rights: Common Ground and Key Divergences

• Common Ground: All three laws have converged on a core set of consumer rights, including the right to access, correct, and delete their personal data, as well as the right to data portability (obtaining a copy of their data).

• Key Divergences: The uniquely American concept is the "Right to Opt-Out of Sale/Sharing." Both the CCPA/CPRA and TDPSA give consumers the power to stop businesses from selling their data or using it for targeted advertising. The GDPR handles this differently by requiring a strict lawful basis for such processing in the first place, making a separate "opt-out" right less necessary.

4. Business Obligations: A Unified Direction

All three frameworks require businesses to be more accountable for their data practices. Key shared obligations include:

• Data Protection Assessments: All three mandate conducting risk assessments (known as DPAs or DPIAs) for high-risk processing activities.

• Vendor Management: Businesses are required to have contracts (Data Processing Agreements) in place with any vendors that process data on their behalf.

• Transparency: All require a clear and comprehensive privacy notice that informs consumers about their data collection practices and their rights.

The Path Forward: A Unified Platform for Global Compliance

Juggling the nuanced differences between these major regulations with separate systems or spreadsheets is a recipe for failure. A cohesive global strategy requires a unified data governance platform.

Walla is designed to be the central hub for managing multi-jurisdictional compliance:

• Flexible Consent Management: Our platform can be configured to manage the strict "opt-in" consent required by the GDPR and TDPSA for sensitive data, while also handling the "opt-out" and "limit use" requests under the CCPA/CPRA.

• Centralized Rights Management: Walla provides a single source of truth for your customer data, making it simple to efficiently respond to access, deletion, or portability requests, regardless of where the consumer lives.

• A Universal Security Standard: Walla’s foundational end-to-end encryption, granular access controls, and comprehensive audit trails provide a high standard of security that helps meet the stringent requirements of all three regulations.

While global privacy laws are aligning on core principles, their operational differences demand a sophisticated, flexible approach. A "one-size-fits-all" compliance strategy is no longer viable. By understanding the key distinctions and leveraging a unified platform to manage them, you can build a compliance program that is as global as your business.