International data privacy compliance has become increasingly complex as multinational organizations must look beyond domestic borders. The European Union (EU) continues to set the global benchmark with updates to the General Data Protection Regulation (GDPR) and new AI-specific data protection rules under the EU AI Act. These developments introduce heightened expectations for compliance, especially in the realm of cross-border data transfers and algorithmic accountability.
Here is an update on international developments in data privacy, focusing on the EU’s role, global transfer mechanisms, and emerging AI regulations:
EU GDPR Updates: Raising Global Standards for International Data Privacy Compliance
Since its inception, the GDPR has been the foundation of international data privacy law. In 2025, the EU has reinforced compliance obligations by:
- Strengthening enforcement for multinational corporations.
- Introducing enhanced consent standards and transparency requirements.
- Expanding data subject rights, particularly around automated decision-making.
For global businesses, this means compliance strategies must be more granular, transparent, and enforceable across jurisdictions. Even non-EU organizations that process EU residents’ data must ensure they align with these heightened requirements.
AI-Specific Data Protections
A major development in 2025 is the EU’s introduction of AI-focused data protections. Regulators now require that algorithms processing personal data must:
- Operate ethically by preventing bias or discrimination.
- Maintain fairness in automated decision-making.
- Provide transparency, allowing users to understand how their data is being used.
Embedding privacy by design into AI systems is no longer optional. From product development to deployment, organizations must demonstrate compliance at every stage of the AI lifecycle. Beyond regulatory compliance, this approach also fosters consumer trust and strengthens brand reputation.
Cross-Border Data Transfer Challenges
Global businesses often depend on data moving seamlessly across borders. However, with increasing restrictions, organizations must adopt legally recognized transfer mechanisms such as:
- Standard Contractual Clauses (SCCs): Pre-approved contractual obligations ensuring compliance across borders.
- Binding Corporate Rules (BCRs): Internal codes of conduct for multinational organizations, reviewed and approved by regulators.
Failure to use these mechanisms can expose businesses to enforcement actions, fines, and reputational harm. Organizations must regularly review transfer practices and ensure documentation is up-to-date and audit-ready.
Practical Steps for Compliance Leaders
To effectively navigate international data privacy requirements, compliance leaders should:
- Map Global Data Flows
– Identify where personal data resides, how it moves, and what jurisdictions it touches. - Evaluate AI Initiatives
– Conduct audits of algorithms that are processing personal data, documenting fairness, bias checks, and transparency measures. - Strengthen Documentation
– Maintain detailed records of cross-border transfer mechanisms, privacy policies, and AI governance frameworks. - Leverage Legal Support
– Using legal support partners can help manage ongoing research, compliance monitoring, and contract reviews, ensuring efficiency and cost-effectiveness while meeting global requirements.
As global regulations evolve, multinational organizations must view compliance not as a checkbox, but as an integrated business strategy. The EU’s updated GDPR requirements, AI-specific protections, and stricter cross-border rules demand a proactive approach.
International data privacy compliance requires a proactive, integrated approach that aligns legal, technical, and operational teams across jurisdictions. By partnering with Baer Reed, law firms and corporations can ensure their compliance strategies keep pace with global changes while freeing internal teams to focus on higher-value priorities. Speak to our data privacy team today.
Mr. Reyes graduated with honors from the Ateneo de Manila University, where he received the Procter and Gamble Student Excellence Award. He obtained his Juris Doctor degree from the Ateneo de Manila School of Law. During law school, Mr. Reyes was part of the Philippine delegation to the Willem C. Vis International Commercial Arbitration Moot held in Vienna, Austria. He was also a member of the Ateneo Society of International Law and the St. Thomas More Debate Society. He completed his internship at the Public Attorney’s Office. He wrote a thesis entitled: “To Kill A White Elephant: An Analysis of the Fiduciary Exception to the Corporate Attorney-Client Privilege”. Mr. Reyes is admitted to practice law in the Philippines and the State of New York.
Matthew Hersh earned a B.A. in Political Science from Columbia University in 1990 and graduated cum laude from Georgetown University Law Center in 1999. He also holds a master’s degree in international relations from the Georgetown University School of Foreign Service.
Cap. Avi Levak (Res. IDF) graduated from from Israel’s prestigious Ben-Gurion University of the Negev with a Bachelor of Science in Computer Science and Mathematics. He is also a Leadership and Communication coach trained in TuT coaching by Alon gal in Israel. Avi specializes in high-level, in-depth analysis of business and client needs, within systems and software strategy and architecture.
Ms. Lardizabal-Manzano is a graduate of San Sebastian College-Recoletos, where she earned her B.A. in Political Science. In 2003, she received her law degree from Lyceum of the Philippines and was admitted to practice law in 2004.
Mr. De Guzman graduated from San Beda College with a degree of Bachelor of Arts Major in Economics and received his law degree from San Beda College of Law. He is multilingual and is fluent in three languages: Chinese, Filipino, and English. He was admitted to the Philippine Bar in 2003.
Ms. Aquino-Batallones obtained a Bachelor of Arts degree in Development Studies (with Minors in Global Politics and Hispanic Studies) from the Ateneo de Manila University. In 2011, she received her Juris Doctor degree from Ateneo de Manila University School of Law. During law school, she interned at Romulo Mabanta Buenaventura Sayoc & de los Angeles then became an intern of Ateneo Legal Services Center’s Clinical Legal Education Program.
Ms. Cruz-Anonuevo graduated cum laude and top nine in her batch from Miriam College with a degree of Bachelor of Arts in InternationalStudies. She obtained her Juris Doctor degree from Ateneo de Manila University School of Law in Rockwell. During law school, she interned in Rivera, Santos, Maranan & Associates. She was also part of Ateneo’s Labor Law Bar Operations. She wrote her thesis on, “Stealing Privacy: Limitations on Media’s Photographic Invasion.,” Ms. Cruz-Anonuevo is admitted to practice law in the Philippines.
Ms. Tyler graduated cum laude from Georgetown University and received her law degree, cum laude, from Georgetown University Law Center. During law school, she interned at the United Nations Economic Commission for Europe. She also worked on The Tax Lawyer journal and was a member of the award-winning Barristers’ Council Mock Trial Team. Ms. Tyler is admitted to practice law in the State of California and the District of Columbia.