Harvest Cross-Border Regulatory Comparison Report

This is a model report showing the expected format, analysis depth, and writing style for your regulatory comparison assignment coming up next.

Study this example carefully and notice:

How the report is organized into clear sections
The professional but accessible writing style
How regulations are explained in simple terms
The practical recommendations for the company
The balance between Mexican and US requirements
How sources are cited appropriately

Cross-Border Regulatory Analysis: Harvest Market Entry into Mexico

This report analyzes data privacy regulatory requirements for Harvest App, Inc., a New York-based time tracking software company, as they prepare to enter the Mexican market. Harvest provides time tracking, invoicing, expense tracking, and time-based reporting services to over 73,000 businesses worldwide. The company has approached our consulting firm to understand how Mexican data privacy laws compare to United States requirements, specifically focusing on personal data protection regulations that will affect their expansion plans.

This report examines Mexico’s Federal Law for the Protection of Personal Data Held by Private Parties (LFPDPPP) and compares it to relevant United States privacy regulations. Understanding these differences is crucial for Harvest’s successful market entry, as the company will need to adapt their data collection, storage, and processing practices to comply with Mexican law while maintaining their existing US operations.

Key Business Regulations in Mexico

Mexico’s Federal Law for the Protection of Personal Data Held by Private Parties (LFPDPPP) was completely updated in March 2025, replacing the previous 2010 law. This regulation governs how private companies like Harvest can collect, process, and store personal information from Mexican users.

The LFPDPPP requires businesses to obtain informed consent before collecting personal data and to provide clear privacy notices explaining how the data will be used. Companies must implement organizational and technical security measures and provide mechanisms for individuals to exercise their ARCO rights: Access, Rectification, Cancellation, and Objection. The law also includes data portability rights, allowing users to request their data in a machine-readable format.

For a company like Harvest, this means they must clearly explain to Mexican users what time tracking data they collect, how it will be stored and used, and provide easy ways for individuals to access, correct, or delete their personal information.

The LFPDPPP applies to all businesses that collect personal data from Mexican residents, regardless of where the company is located. This means Harvest will need to comply with Mexican law as soon as they begin serving Mexican customers, even while operating from their New York headquarters.

Corresponding Regulations in the United States

The United States does not have a single comprehensive federal data privacy law like Mexico’s LFPDPPP. Instead, the US has a patchwork of federal and state regulations that apply to different industries and situations.

At the state level, California’s Consumer Privacy Act (CCPA) provides the most comprehensive privacy protections in the US, giving California residents rights to know what personal information businesses collect, request deletion of their data, and opt out of the sale of their personal information. Several other states have passed similar laws, but these only apply to residents of those specific states.

For Harvest, this means their current US operations are primarily governed by California state law since they serve California customers. The company likely already has privacy policies and data security measures in place to comply with CCPA requirements, but these may not be sufficient for Mexican law compliance.

The key difference is that Mexico’s LFPDPPP provides nationwide, comprehensive data protection requirements, while US privacy regulations are fragmented by state and industry. Mexico’s approach is more similar to European Union privacy laws than to the current US regulatory environment.

Recommendations

Based on our regulatory comparison, we recommend the following steps for Harvest’s market entry into Mexico:

Immediate Actions: Harvest should conduct a comprehensive audit of their current data collection and privacy practices to identify gaps with Mexican requirements. They need to create Mexico-specific privacy notices in Spanish that clearly explain what employee data they collect, how it is used, and provide easy mechanisms for Mexican users to exercise their ARCO rights. The company should also establish a process for responding to Mexican user requests for data access, correction, or deletion within the timeframes required by Mexican law.
Technical Implementation: The company should implement technical measures to ensure Mexican user data is handled according to LFPDPPP requirements. This includes updating their consent mechanisms to meet Mexican standards and ensuring their data security measures are adequate for Mexican law. Harvest should also consider appointing a data protection contact person who can handle Mexican regulatory communications and user requests in Spanish.
Ongoing Compliance: Harvest needs to monitor changes in Mexican data privacy regulations and ensure their practices remain compliant as the law evolves. They should train their customer service team on Mexican privacy rights and establish procedures for handling data breach notifications according to Mexican requirements. The company should also review their contracts with any third-party service providers to ensure these relationships comply with Mexican data transfer restrictions.

Conclusion

The main difference between Mexico and California is that Mexico has one clear set of privacy rules for the whole country, while California’s law is often complied with by U.S. companies because their consumers include California residents. For Harvest, this means they need to learn Mexican requirements but can build on their existing experience with California’s CCPA since both laws give users similar rights to control their personal data.

Entering the Mexican market is realistic for Harvest from a regulatory perspective. The company already has privacy policies and data security measures for their California customers, which provides a good starting point for Mexican compliance. With proper planning and the recommended steps, Harvest can successfully follow Mexican privacy laws while continuing to provide excellent time tracking services to Mexican businesses.

Works Consulted

Data Protection Laws and Regulations Mexico 2025. ICLG. July 2025.

Data Protection in Mexico: Federal Law for the Protection of Personal Data Held by Private Parties (FLPPDHPP). European Commission. July 2024.

Ley Federal de Protección de Datos Personales en Posesión de los Particulares. Mexico Federal Government. March 2025.

What is the California Consumer Privacy Act (CCPA)? IBM.

California Consumer Privacy Act (CCPA). State of California Department of Justice. 2025. October 2023.

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