Beyond Lexical Equivalence: A Corpus Semantic Analysis of ‘Privacy’ and ‘Data Protection’ Across Jurisdictions
摘要
The transboundary nature of data flows necessitates a nuanced understanding of core legal concepts across jurisdictions. While terms like “privacy” and “data protection” are often used interchangeably in global discourse, this study posits that they embody distinct, jurisdictionally specific semantic and conceptual structures. Moving beyond traditional doctrinal comparison, this research employs a novel computational linguistics and corpus semantics framework to analyze a curated digital corpus comprising the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and China’s Personal Information Protection Law (PIPL). Through keyword co-occurrence network analysis and conceptual mapping, we quantitatively delineate the semantic fields and conceptual networks surrounding core terms. Our findings reveal a fundamental schism: the GDPR constructs a dense, rights-centric conceptual network around “personal data,” deeply intertwined with human dignity; the CCPA orbits around a market-oriented concept of “consumer” and “sale,” framing privacy as a commodifiable good; and the PIPL foregrounds “personal information” within a framework of state security and social management. This study demonstrates the power of data-driven methods to uncover the implicit architectural logics of legal systems, offering a more granular and empirically grounded basis for understanding legal interoperability and conflict in the digital age.