Before we start comparing, it’s worth highlighting that this is a bit of an “oranges & apples” thing because, technically speaking, the UK DPA (Data Protection Act) 1998 was enacted to bring British law into line with the 1995 EU DPD (Data Protection Directive, aka 95/46/EC) which is the one that is, now, being repealed and superseded by the GDPR (General Data Protection Regulation, aka 2016/679) that was adopted in 2016.