Comparing and Conceptualizing Data Protection Requirements Worldwide for Privacy Regulatory Compliance
The growing digitalization of society has intensified the collection, processing, and sharing of personal data, increasingly moving across national borders and regulatory jurisdictions, prompting a proliferation of data protection frameworks worldwide. These transborder personal data flows (TPDF) are essential to today's economy, but organizations managing them must reconcile data protection requirements that differ, sometimes subtly, across jurisdictions. For requirements engineering, this is the central challenge: regulatory data protection requirements (RDPRs) are complex and not directly translatable into software requirements, especially when frameworks impose similar, non-identical, or contradictory obligations. Identifying which requirements are shared and which diverge is therefore critical to managing TPDF, and addressing them late in the software development lifecycle (SDLC) causes costly rework, making early identification essential for compliance and stakeholder communication. This paper identifies and conceptualizes common RDPRs worldwide from the perspective of data protection legal experts, answering: (SQ1) which requirements are common across regulations and how are they conceptualized, and (SQ2) which requirements diverge and how do they differ conceptually. We combine deductive qualitative analysis of interviews with 70 legal experts from G20 economies and other countries and systematic content analysis of these economies' data protection regulations. We identify common requirements, such as consent, and divergent ones, such as the right to be forgotten. Given their impact across the SDLC and enterprise architecture, we translate these findings into a set of Data Protection Officer DPO (DPO) stories, using the user story notation, classified by SDLC phase and enterprise architecture layer, to help organizations manage TPDF compliance.