This article is devoted to the analysis of the legal framework for the protection of digital rights in Kazakhstan and foreign countries. The relevance of the research is determined by the rapid development of digitalization and the need to safeguard individual rights online, including the protection of personal data, digital identity, freedom of expression, and access to information. In Kazakhstan, several normative acts on information security and personal data have already been adopted; however, their regulation remains fragmented. In foreign practice (EU, USA, South Korea), a more systematic approach is observed. The purpose of the study is to identify the problems of Kazakhstani legislation and propose ways to improve it, considering international experience. The novelty of the research lies in the comprehensive comparative legal analysis of digital rights, while its practical significance consists in the possibility of applying the findings to modernize national legislation.